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PA Prison Might Unconstitutionally Restrict Prisoners’ Court Access

William Bryan, a Pennsylvania state prisoner, sued prison officials in federal district court under 42 U.S.C. 1983, claiming that they denied him adequate access to the courts. Legal business was conducted through a prisoner-staffed law clinic which was not allowed to help prisoners litigate tort-based actions against the prison. The district court found that although Bryan may have no access to the prison law library, he could still file civil complaints in court, and thus had adequate court access. Bryan’s civil rights action was dismissed, and he appealed.

On appeal, the U.S. Court of Appeals for the 3rd Circuit held that since the clinic couldn’t litigate prisoners’ civil actions, denying Bryan law library access, and/or not allowing him to mail legal correspondence to the courts would unconstitutionally restrict his court access. The district court was therefore reversed and the case remanded. See: Bryan v. Werner, et al, 516 F.2d 233 (3d Cir. 1975).

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Related legal case

Bryan v. Werner