Inmate's access-to-the-courts claim denied by federal judge

By Jon Campisi | Oct 29, 2012

A federal judge has dismissed a pro se civil action that had been initiated

A federal judge has dismissed a pro se civil action that had been initiated

against a suburban Philadelphia prison and its officials by an inmate who claimed he was denied proper access to the courts.

Darren L. Cephas initiated a complaint against the Delaware County Prison, George W. Hill Correctional Facility back in January 2010 over claims that the prison’s law library had provided him with outdated legal forms, resulting in a hindrance to the plaintiff’s efforts to receive bail and defend a separate criminal action.

Cephas also alleged that he sustained high levels of stress because of the action on the part of the prison.

The additional defendants named in the suit were prison Warden Frank Green and Dana Keith, the prison’s law clerk.

The complaint alleged that the plaintiff’s constitutional right of access to the courts was violated through the defendants’ actions.

In an Oct. 25 order, U.S. District Judge Mitchell S. Goldberg, of the Eastern District of Pennsylvania, granted the defendants’ motion for summary judgment.

The judge simultaneously denied the plaintiff’s request for counsel.

In his memorandum and opinion, Goldberg wrote that the court agreed with the defendants that contrary to Cephas’ allegations, the plaintiff was, in fact, provided with the correct legal forms with which to pursue his habeas corpus motion, something that was reflected in the court dockets.

The defendants had also argued that Cephas’ allegation that the alleged problems with his motion interfered with his ability to receive bail and defend a separate criminal action was not sufficient to state an “actual injury,” something that is required in a constitutional access-to-the-courts case such as this.

Goldberg wrote that a review of the court docket shows that Cephas was not prevented from pursing his Section 2255 habeas corpus motion.

The judge further determined that the plaintiff’s appellate court docket demonstrates that he was, indeed, represented by legal counsel, and thus his right of access to the courts is satisfied as a matter of law.

As far as the requirement to state a “proper injury,” Goldberg wrote that the “injury requirement is not satisfied by the frustration of any type of legal claim; it is limited to the hindrance of direct appeals, habeas petitions and [Section] 1983 claims. Thus, any interference with Plaintiff’s ability to receive bail or defend a separate criminal action is not actionable.”

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