The following excerpt is from Smith v. Cobb, Case No.: 3:15-cv-00176-GPC-WVG (S.D. Cal. 2017):
An essential element to a prisoner's access to court claim is that the prisoner has experienced an actual injury as a result of the officials' interference. Lewis v. Casey, 518 U.S. 343, 349-56 (1996). This "is a jurisdictional requirement that flows from the
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