Bounds v. Smith

Robert Smith, Donald Morgan, and John Harrington (plaintiffs) were inmates at prisons operated by the North Carolina Department of Corrections (department) (defendant). The inmates filed separate actions against the department, alleging that the department’s failure to provide legal research facilities effectively deprived inmates of access to the courts in violation of the Fourteenth Amendment. The state had only one prison library and no programs offering other legal assistance to prisoners. The actions were consolidated, and the district court granted summary judgment in the inmates’ favor, instructing the department to develop a program assuring that inmates had access to the courts. In response, the department proposed to establish seven law libraries across the state, with prisoners being able to request appointments at those libraries and the department providing the transportation and housing needed for one full day’s library work. The department also proposed to train prisoners as research assistants and typists to help other prisoners. An estimated 350 prisoners would be able to visit a library each week, although there might be up to a four-week wait for a library slot. The inmates claimed that the plan was inadequate and asked that the district court order the creation of a law library in every prison. The district court denied that request, concluding that the state’s proposed system was sufficient to provide prisoners with reasonable access to the courts. It also held that the department was not required to provide any additional legal assistance outside of library access. The Fourth Circuit affirmed the sufficiency of the department’s proposed library plan with one modification requiring that women prisoners have equal access. The United States Supreme Court granted certiorari.