Samantha Sabers v. Lynne Delano, 100 F.3d 82 (8th Cir. 1996). · Go Syfert
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Samantha Sabers v. Lynne Delano, 100 F.3d 82 (8th Cir. 1996). Cases Citing This Book View Copy Cite
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A prisoner must demonstrate that inadequate legal resources actually hindered efforts to proceed with a specific legal claim to establish standing for an access-to-courts claim.

An inmate sues prison officials under 42 U.S.C. § 1983, alleging that the facility’s contract attorney and lack of a law library violated her constitutional right of access to the courts. The district court grants summary judgment, finding the plaintiff failed to demonstrate concrete injury. On appeal, the court addresses whether a systemic denial of legal resources alone establishes a constitutional violation. Applying the rule that a plaintiff must show actual prejudice to a specific legal claim, the court holds that the inmate cannot rely solely on allegations of inadequate assistance. Because she offers no facts indicating the attorney’s shortcomings hindered her efforts to proceed with a criminal appeal, postconviction matter, or civil rights action, she lacks standing. The court affirms the judgment below.

85 citation events (77 in the last 25 years) across 15 distinct courts.
Strongest positive: Winter, No. 4:25-cv-00299 (E.D. Mo. Dec. 18, 2025)
Treatment trajectory · 1997 → 2026 · click a year to view as-of
1997 2011 2026
How cited ↗
Cited for
At page 84 Establishing standing for access to courts claims30 citing cases“efforts to proceed with a legal claim in a criminal appeal, postconviction matter, or civil rights action seeking to vindicate basic constitutional rights.”7 citing courts quote it · 29 listed here
  • Winter, No. 4:25-cv-00299 (E.D. Mo. Dec. 18, 2025).
    (Absent standing to bring the claim in her own right, [the plaintiff] is not eligible to represent a class of persons raising the same claim.)
  • Krumback, No. 4:24-cv-04156 (D.S.D. Sept. 23, 2026).
    See White, 494 F.3d at 681 n.3 (declining to consider whether a prisoner had been denied meaningful access to the courts because the prisoner did not demonstrate that he suffered an actual injury and “thus no jurisdictional standing[.]”);…
  • Reynolds, No. 4:26-cv-00633 (E.D. Ark. Aug. 4, 2026).
    Johnson v. State of Mo., 142 F.3d 1087 , 1088-91 (8th Cir. 1998); Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996).
  • Rollins, No. 1:25-cv-00105 (E.D. Mo. May 4, 2026).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (citing Lewis v. Casey, 518 U.S. 343 , 353 n.4 (1996)).
  • Npimnee, No. 8:23-cv-00102 (D. Neb. Dec. 31, 2025). 2 cites
    Iowa 2024) (quoting Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996)).
  • Goldsboro v. Doe, No. 6:25-cv-00825 (M.D. Fla. Aug. 5, 2025).
    However, “in an access-to-courts claim, ‘a plaintiff cannot merely allege a denial of access to a law library or adequate attorney, even if the denial is systemic.’” Wilson v. Blankenship, 163 F.3d 1284, 1291 (11th Cir. 1998) (quoting Sabe…
  • Anderson v. Hernandez, No. 1:23-cv-00201 (E.D. Mo. June 18, 2024).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (per curiam) (citing Lewis v. Casey, 518 U.S. 343, 351 (1996)).
  • Graves v. Zandlo, No. 4:23-cv-01024 (E.D. Mo. Dec. 19, 2023).
    As such, Plaintiff presents no evidence, nor can the Court find any evidence in the state court records, that Plaintiff suffered an injury to a “viable legal claim.” See Sabers, 100 F.3d at 84.
  • Jackson v. Cape Cnty. Jail, No. 1:22-cv-00085 (E.D. Mo. Oct. 31, 2022).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (citing Lewis v. Casey, 518 U.S. 343 , 353 n.4 (1996)).
  • Baalim v. St. Louis City Just. Ctr., No. 4:22-cv-00359 (E.D. Mo. June 22, 2022).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (citing Lewis, 518 U.S. at 353 n.4).
Show 19 more citing cases
  • Burke v. St. Louis Cnty. Jail, No. 4:22-cv-00351 (E.D. Mo. May 27, 2022). 2 cites
    The Eighth Circuit has recognized that, when bringing an access to courts claim, it is insufficient to allege a denial of access to a specific resource, “even if the denial is systemic.” Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (p…
  • Koonce v. Satterfield, No. 1:22-cv-00007 (E.D. Mo. Apr. 25, 2022).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (citing Lewis, 518 U.S. at 353 n.4).
  • Santais v. Core Civic, Inc., No. 5:18-cv-00055 (S.D. Ga. Sept. 23, 2021).
    In other words, “in an access-to-courts claim, ‘a plaintiff cannot merely allege a denial of access to a[n adequate] law library . . . , even if the denial is systemic.’” Wilson, 163 F.3d at 1291 (quoting Sabers v. Delano, 100 F.3d 82, 84…
  • Goldstein v. McKee, No. 4:21-cv-00408 (E.D. Mo. Sept. 17, 2021).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (citing Lewis, 518 U.S. at 353 n.4).
  • Cook v. Redington, No. 2:20-cv-00071 (E.D. Mo. May 5, 2021).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (citing Lewis, 518 U.S. at 353 n.4).
  • Winston v. Edwards, No. 4:20-cv-00566 (E.D. Mo. Dec. 11, 2020).
    Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (per curiam) (citing Lewis, 518 U.S. 343 ).
  • Holmes v. Shearouse, No. 4:19-cv-00135 (S.D. Ga. Nov. 9, 2020).
    Denial-of-access-to-the-courts claims require a showing of actual injury. “‘[A] plaintiff cannot merely allege a denial of access to a law library or adequate attorney, even if the denial is systemic.’ Rather, a plaintiff must demonstrate…
  • Pratt v. Corr. Corp. of Am. Corp. Headquarters, 104 F. App'x 611 (8th Cir. 2004).unpublished
    Upon de novo review, we conclude that the district court 1 correctly dismissed Pratt’s access-to-courts claim because he did not allege that defendants prevented him from asserting a claim in a “criminal appeal, postconviction matter, or c…
  • Martin v. Ellandson, 122 F. Supp. 2d 1017 (S.D. Iowa 2000).published
    Lewis v. Casey, 518 U.S. 343, 349 , 116 S.Ct. 2174 , 135 L.Ed.2d 606 (1996); Sabers v. Delano, 100 F.3d 82, 84 (8th Cir.1996).
  • Arce v. Walker, 58 F. Supp. 2d 39 (W.D.N.Y. 1999).published
    However, courts have also cited Lewis as supporting the right to “proceed with a legal claim,” Wilson v. Blankenship, 163 F.3d 1284, 1291 (11th Cir.1998) (quoting Sabers v. Delano, 100 F.3d 82, 84 (8th Cir.1996)), which suggests, at least,…
  • Wilson v. Blankenship, 163 F.3d 1284 (11th Cir. 1998).published 2 cites
    Therefore, in an aceess-to-courts claim, “a plaintiff cannot merely allege a denial of access to a law library or adequate attorney, even if the denial is systemic.” Sabers v. Delano, 100 F.3d 82, 84 (8th Cir.1996) (per curiam).
  • Taylor v. Redington, No. 2:22-cv-00008 (E.D. Mo. June 8, 2022).
    See Sabers, 100 F.3d at 84, Hartsfield, 511 F.3d at 833 .
  • Engel v. CO1, No. 4:20-cv-01733 (E.D. Mo. Mar. 17, 2021).
    (concluding that because the plaintiff suffered no cognizable injury, she lacked standing to bring an access-to-courts claim)
  • Thomas-El v. Precynthe, No. 2:19-cv-00049 (E.D. Mo. Sept. 16, 2019).
    See Lewis, 518 U.S. at 351 , Sabers, 100 F.3d at 84.
  • Ronaldo S. Ligons v. David Crist, 82 F. App'x 504 (8th Cir. 2003).unpublished
    See Sabers v. Delano, 100 F.3d 82, 84 (8th Cir.1996) (per curiam). 1 .
  • Glaum, No. 1:24-cv-00146 (D.N.D. Mar. 31, 2026).
    See also Sabers v. Delano, 100 F.3d 82, 84 (8th Cir. 1996) (per curiam) (“[w]hen bringing an access-to-courts claim . . . the plaintiff must show the lack of a library or the attorney’s inadequacies hindered the plaintiff’s efforts to proc…
  • Fred Louis Lamp v. State of IA, No. 96-2946 (8th Cir. Aug. 13, 1997).published
  • Owens v. Wilcher, No. 4:21-cv-00295 (S.D. Ga. June 2, 2022).
  • Myers v. Wilcher, No. 4:21-cv-00254 (S.D. Ga. June 2, 2022).
Other citing cases15 with no pin cite or quoted language on record
Show 5 more citing cases
Retrieving the full opinion text from the archive…
Samantha SABERS, Plaintiff-Appellant, Lora Davis, Plaintiff,
v.
Lynne DELANO, in Both Her Official and Individual Capacity; Jim Smith, in Both His Official and Individual Capacity; Darryl Slykhuis, in Both His Official and Individual Capacity; Robert Dooley, in Both His Official and Individual Capacity; Don Irish, in Both His Official and Individual Capacity; Tami Vonsik, in Both Her Official and Individual Capacity; Amy Bradley, in Both Her Official and Individual Capacity; Sally Boyd, in Both Her Official and Individual Capacity; William Minder, in Both His Official and Individual Capacity; Cheryl Martens, in Both Her Official and Individual Capacity; John Kuckleburg, in Both His Official and Individual Capacity; Dallas Schneider, in Both His Official and Individual Capacity, Defendants-Appellees
95-3806SD.
Docket on CourtListener (RECAP)
Court of Appeals for the Eighth Circuit.
Oct 30, 1996.
Published opinion
100 F.3d 82
1996 U.S. App. LEXIS 27954
Steven K. Rabuck, Sioux Falls, SD,' for appellant., Frank Geaghan, Pierre, SD, for appellees.
Fagg, Heaney, Hansen.
Cited by 1 opinion  |  Published
PER CURIAM.

Samantha Sabers, an inmate at the Springfield Correctional Facility (SCF) in South Dakota, brought this 42 U.S.C. § 1983 action against various SCF officials alleging they violated her constitutional right of access to the courts under Bounds v. Smith, 430 U.S. 817, 828, 97 S.Ct. 1491, 1498, 52 L.Ed.2d 72 (1977) (prison authorities must provide inmates with adequate law libraries or adequate assistance from persons trained in the law). Although the SCF provided inmates with a contract attorney to assist them in legal matters, Sabers alleged the attorney’s services were inadequate because of his work experience and library resources. Sabers asked the district court to enter an order directing the SCF officials to provide a law library at the SCF, along with instructional books and training sessions. Later, Sabers moved for leave to amend her complaint to bring her lawsuit as a class action. After conducting a hearing on both motions, the[*84] district court held Sabers failed to show any concrete injury from the alleged constitutional violation. The district court thus granted the SCF officials’ motion for summary judgment and denied Sabers’s motion to amend her complaint as moot.

On appeal, Sabers contends that she and other prisoners are systematically denied access to the courts, and thus she need not show the lack of a law library or the attorney’s inadequate assistance actually injured her. See Jones v. James, 38 F.3d 943, 945 (8th Cir.1994). The Supreme Court recently rejected this contention in Lewis v. Casey, — U.S. -, -, - n. 4, 116 S.Ct. 2174, 2180, 2181 n. 4, 135 L.Ed.2d 606 (1996). When bringing an access-to-courts claim, a plaintiff cannot merely allege a denial of access to a law library or adequate attorney, even if the denial is systemic. Id. Instead, the plaintiff must show the lack of a library or the attorney’s inadequacies hindered the plaintiffs efforts to proceed with a legal claim in a criminal appeal, postconvietion matter, or civil rights action seeking to vindicate basic constitutional rights. Id. at - - -, 116 S.Ct. at 2181-82. The Constitution does not require a state to “enable [a] prisoner to discover grievances, and to litigate effectively once in court.” Id. at -, 116 S.Ct. at 2181. Sabers has offered no facts indicating the attorney’s alleged shortcomings or the lack of a law library prejudiced her in a legal case. Because Sabers suffered no cognizable injury, she lacked standing to bring the aceess-to-courts claim. Id. at -, 116 S.Ct. at 2179. Absent standing to bring the claim in her own right, Sabers is not eligible to represent a class of persons raising the same claim. Foster v. Center Township of LaPorte County, 798 F.2d 237, 244 (7th Cir.1986); see East Texas Motor Freight Sys., Inc. v. Rodriguez, 431 U.S. 395, 403-04, 97 S.Ct. 1891, 1896-97, 52 L.Ed.2d 453 (1977). We affirm the district court.