The following excerpt is from Sule v. FCI Sheridan, 92 F.3d 1194 (9th Cir. 1996):
A prisoner must establish actual injury from denial of access to the courts to establish a cognizable constitutional violation. Sands v. Lewis, 886 F.2d 1166, 1171 (9th Cir.1989). Sule has not shown any actual injury.
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