Lewis v. Fletcher

LOCATION: North Carolina General Assembly

DOCKET NO.: 94-1511
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 518 US 343 (1996)
ARGUED: Nov 29, 1995
DECIDED: Jun 24, 1996

Elizabeth Alexander - Argued the cause for the respondents
Grant Woods - Argued the cause for the petitioners

Facts of the case

Fletcher Casey, Jr. and other inmates of various prisons operated by the Arizona Department of Corrections (ADOC), brought a class action against ADOC officials, alleging that the ADOC officials were furnishing them with inadequate legal research facilities and thereby depriving them of their right of access to the courts, in violation of Bounds v. Smith. Bounds held that "the fundamental constitutional right of access to the courts requires prison authorities to assist inmates in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law." The District Court found the ADOC officials in violation of Bounds and issued an injunction mandating detailed, systemwide changes in ADOC's prison law libraries and in its legal assistance programs. The Court of Appeals affirmed both the finding of a Bounds violation and the injunction's major terms.


Did a federal trial judge err when ruling that Arizona prison officials unconstitutionally failed to provide inmates with adequate legal research facilities?

Media for Lewis v. Fletcher

Audio Transcription for Oral Argument - November 29, 1995 in Lewis v. Fletcher

William H. Rehnquist:

We'll hear argument next in Number 94-1511, Samuel A. Lewis v. Fletcher Casey.

General Woods.

Grant Woods:

Mr. Chief Justice, and may it please the Court:

This is an inmate access to the court case.

The State of Arizona meets and exceeds the requirements of Bounds v. Smith by providing at the time of trial 26 law libraries at nine separate prison complexes across the State.

As the prison population has grown from more than 15,000 to 22,000 prisoners, we have added seven more libraries, for a total of 33.

In addition to providing adequate legal resources to the inmates through these law libraries, Arizona goes above and beyond the requirements of Bounds by facilitating the use of legal clerks and legal assistants to obtain books and to help in the preparation of lawsuits.

Also, we encourage inmates to take our classes to teach them to read English, and we find interpreters for non-English-speaking inmates.

We facilitate also assistance from family, from friends, outside lawyers and paralegals and other prisoner rights groups.

Although deference to State officials in the area of prison administration is required by this Court, the district court in this case has imposed an order which micromanages virtually every aspect of prison life in this area.

Additionally, the district court has entered its order despite a record that has not established an injury warranting systemic relief.

The result is that the order is overbroad, overreaching, and far beyond the requirements of Bounds.

Sandra Day O'Connor:

Mr. Woods, what are the findings of the district court that would support a system-wide violation of Bounds?

Was there any express finding that there was a system-wide violation of the requirements this Court set forth in Bounds?

Grant Woods:

We believe there is not, Justice O'Connor.

The record in this case is difficult, and it's difficult for a variety of reasons, but one reason is because it's difficult to separate pure findings of fact from the judge's order, from how he has extrapolated that based upon, we believe, his misinterpretation of what Bounds requires.

If the Court--

Sandra Day O'Connor:

Well, you take the position that Bounds was an either-or situation, that the State can provide a library or assistance?

Grant Woods:


David H. Souter:

Well, Bounds said that in so many words, didn't it?

Grant Woods:


Mr. Chief Justice, I think it's important for the Court to look at the reasoning behind Bounds, and how it's been--

Sandra Day O'Connor:

Well, if you do that, I certainly think there is some indication that a prisoner who cannot read or who does not speak English might not have meaningful access to a library even if it were there, and you want us to take the position that there's no requirement to provide any assistance at all.

Grant Woods:

--Yes, Justice O'Connor.

We believe that's the proper reading of Bounds, although we--

David H. Souter:

You take the position that, if a prisoner is illiterate or is illiterate in English, that that... that the requirements therefore are still satisfied so long as there is, in fact, a library in existence to which the prisoner could resort if he were able to read it, or a legal helper to whom he could turn if he were able to communicate?

Grant Woods:

--That's correct.

We believe Arizona goes far beyond the requirement of Bounds, but we believe that the proper interpretation of Bounds is that a law library, in and of itself, is enough.

David H. Souter:


--So there is no obligation to an illiterate prisoner.