Bounds v. Smith (1977) was a case that expanded the rights of those incarcerated to have adequate legal materials and law libraries. The case followed Avery v. Johnson (1969) which held that correctional facilities could not bar ‘jailhouse lawyers’ from assisting other inmates in filing legal claims. (Carlton & Garrett, 2008). This decision left many questions unanswered and only gave basic guidelines as to what legal research materials inmates had a constitutional right to access (Carlton & Garrett, 2008). Bounds v. Smith (1977) clarified several previous decisions. The holding was that correctional facilities have to assist inmates in filing suits either by providing adequate law libraries or with assistance from person that have trained in the legal system…show more content… This right can be satisfied by having a law library or providing assistance by persons that have legal training (Carlton & Garrett, 2008). The average cost of starting a prison law library is $60,000 -$70,000 (Tubbs, n.d.). This cost has to be shouldered by taxpayers. When convicted and incarcerated inmates surrender many of their rights. While inmates should have access to legal documents necessary for them to prepare their filing, I do not believe that each prison should be required to have its own library. A central library with the necessary legal books and documents available to inmates should have met the standard. Today, many facilities are moving towards electronic libraries to reduce costs (Smith, 2009). This has also brought up problems. In Ohio, a prisoner is filing suit claiming the electronic resources do not adequate because he is computer illiterate (Smith, 2011). This suit will likely fail due to the standard set forth in Lewis v. Casey (1996) that a plaintiff must show an actual injury when alleging a violation of Bounds v. Smith