The author argues that the 1977 United States Supreme Court decision in Bounds v. Smith insufficiently protects the right of prisoners to represent themselves before the courts by failing to require state and federal correctional facilities to establish and maintain adequately stocked prison law libraries and to provide prisoners with the option to use those libraries as their means of gaining meaningful access to the courts.
Steven D. Hinckley, Bounds and Beyond: A Need to Reevaluate the Right of Prison Access to the Courts, 22 U. Rich. L. Rev. 19 (1987).