Bounds v. Smith, 430 U.S. 817 (1977), was a United States Supreme Court case in which the Court tested the basic constitutional right of prison inmates’ access to legal documents prior to court. Prison authorities would consequently be required to provide legal assistance or counsel to inmates, whether it be through a trained legal professional or access to a legal library. Multiple prisoners alleged that they were denied access to the courts due to lack of an adequate legal library and assistance with court related documents.
Background
The case of Bound v. Smith was preceded by Johnson v. Avery, a similar case brought before the U.S. Supreme Court in 1969 concerning, once again, the extent of prisoners’ rights within the confines of a jail or penitentiary. Johnson v. Avery involved a Tennessee convict who petitioned the courts regarding the prison's disciplinary action exacted on the inmate after breaking a prison rule. The rule states, "No inmate will advise, assist or otherwise contract to aid another, either with or without a fee, to prepare Writs or other legal matters. It is not intended that an innocent man be punished. When a man believes he is unlawfully held or illegally convicted, he should prepare a brief or state his complaint in letter form and address it to his lawyer or a judge. A formal Writ is not necessary to receive a hearing. False charges or untrue complaints may be punished. Inmates are forbidden to set themselves up as practitioners for the purpose of promoting a business of writing Writs." The Court ruled in favor of the prisoners. Johnson v. Avery established that the assistance of a prisoner by a prisoner in filing and research of legal papers related to the criminal prosecution of said prisoner was completely legal under the facts of this case.
There have been many cases, similar to Bounds v. Smith, that have established reasonable precedent regarding a prisoner's access to the courts. In the case of Cochran v. Kansas of 1942, it was confirmed that prisoners have a right of access to the courts and the prohibition of this access is unconstitutional. Specifically, Cochran v. Kansas ruled in favor of a petitioner, who was a prisoner, who wished to file with the federal courts a writ of habeas corpus. Again, a similar instance preceded Bounds v. Smith. In Burns v. Ohio of 1959, the Supreme Court ruled that docket and other fees imposed on inmates were constitutional violations. By 1963, in Douglas v. California, the Court even went as far as to rule that a prisoner must be provided legal counsel if it means he will receive a “meaningful appeal.” Time and time again, the rulings of additional court cases have struck down hindrances obstructing the right of prisoners access to the courts.
Conflict
In the case of Bounds v. Smith, respondents of the courts are those incarcerated within the Division of Prisons of the North Carolina Department of Correction. These respondents filed three actions alleging a violation of their Fourteenth Amendment rights through denial of proper avenues to research. Eventually the case was heard at District Court. The courts approved the motion based on a number of valid claims made by the respondents, specifically citing the lack of an adequate prison library system reason enough for a trial. Due to precedent established in, first, Johnson v. Avery, and then Younger v. Gilmore, the courts found that equality under law had been disregarded because of a severe lack of assistance for inmates wishing to prepare legal documents. Specifically in the case of North Carolina's prison system however, the substance of valuable legal assistance was scarce and thus presented a possibly more logistical problem than argued by the respondents. The District Courts did recognize this fact. The District Court ruled that North Carolina must develop and institute a plan that provided inmates with a form of legal assistance that satisfied a degree of Constitutionality. It was suggested to Senators that they create an effective and economic plan possibly providing lawyers and other legal professionals along with the expansion of state law libraries.
And so, the state responded. A proposal designed to redefine the State's legal informational system was drawn up. The establishment of seven new libraries, spread across the state, was planned, along with the creation of additional smaller libraries. Use of the libraries required an appointment. Appointments were preferentially given to those with court dates within the next month. In accordance with the fact that libraries were not always located within prisons, transportation and housing would also be provided by the State.