Bounds v Smith (1977)

Bounds v Smith (1977)

Legal Issue/Question:

The legal issue in the case concerns the protection of prisoners’ rights by the States pertaining their access to the courts through provision with law libraries or alternate sources of legal information. According to Younger v Gilmore case, it is fundamentally a constitutional right to access courts and a requisite for prison authorities to assist inmates in preparing and filing expressive legal papers. The petitioners ask the court to overrule the case to which the court reaffirms its previous decision by declining the invitation. The petitioners are officials from the North Carolina State.

Facts of the Case:

The respondents; Robert Smith, Donald W. Morgan and John Harrington are inmates in incarceration within correctional facilities under the North Carolina Department of Correction. The respondents did filings of three distinct actions which experience consolidation at the District Court for the Eastern District of North Carolina. Allegation by the respondents are in pertinent to denial in accessing the courts by the failure of the States to offer legal enquiry services, a violation of their Fourteenth Amendment right. The District Court grants a motion for summary judgment on the basis of the respondents’ claim, with consideration that the only prison library within State being derisory. During the case proceeding all petitioners; Vernon Lee Bounds, Stanley Blackledge and R.L. Turner are all officials in correctional facilities within the State of North Carolina. The case is given No. 75-915 as the case number with the argument taking place in November 1, 1976 and the decision presented on April 27, 1977, the proceedings happening in the United States Supreme Court.


In its ruling, the Court of Appeal for the Fourth Circuit provides affirmation of the rulings except one instance. The court of appeal finds it constitutional for the inmate (respondents) to be provided with access to the courts through provision of legal enquiry services. Also, the court of appeal reiterates that the State (Petitioners) is not constitutionally mandated to provide legal aid or libraries. Concerning the objection by the petitioners regarding the States proposal of building seven libraries strategically to serve all correctional facilities within the state, the Supreme court upheld the decision of the District Court. The only place of difference between the Supreme Court and District Court ruling is regarding whether the State’s proposed establishments will serve all inmates equally. The Supreme Court concludes that the prison libraries deprived women equal access as men to the facilities. The judgment is made in the ratio of 6:3 with Justice Marshall delivering the majority ruling. Justice Marshall rejected the interpretation of Ross v Moffit by the North Carolina State that held on prisoners’ right to appoint counsel in criminal cases was restricted.

Court’s Rationale:

Drawing reference from Griffin v Illinois, the Supreme Court note that an adequate and effective appellate review is impractical without a trial record or suitable substitute and thus State are to make available trial accounts to inmates’ incapable of buying them. The Supreme Court spells out that it is irrefutable that impoverished inmates get provisions to draft legal documents and notarial services to validate them at the expense of the State. On the petitioners urge to reverse the decision of federal courts to sit as superintendents of state prison, the Supreme Court distinguish that judicial limitation is often apt in convicts’ right cases. The Supreme Court holds that the policy cannot cover any letdown to take knowledge of valid constitutional privileges. The petitioners claim is thus rendered unfitting in this case, as the courts conscientiously respected the parameters on their roles. The court as such did not thrust itself into prison administration, however, ordered the petitioners to create a remedy for the abuse. The petitioners took to create law libraries and the plan permitted with negligible changes over the solid objections of the defendants. The prison commissioners exercised an extensive option within the constraints of constitutional necessities in this case.

Significance of the Case: