Belden v. Lampert
2011 WY 83
Wyo.2011Background
- Belden, acting pro se, filed a 42 U.S.C. § 1983 action alleging denial of meaningful access to the courts due to inadequate Nevada prison law library resources for Wyoming law.
- He claimed the Nevada facility provided Wyoming materials only via LexisNexis discs and exact-cite paging, with staff not trained in Wyoming law.
- The district court dismissed for failure to plead an actual injury and failure to exhaust administrative remedies.
- Belden was convicted of first-degree sexual assault and first-degree murder in Wyoming, with prior direct and collateral appellate proceedings.
- The Wyoming Supreme Court ultimately affirmed the district court’s dismissal; the court held Belden did not allege an actionable injury and did not timely pursue post-conviction relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint shows actual injury from law-library inadequacies. | Belden argues Nevada library hindered post-conviction timing. | Lampert contends no actual injury shown. | Affirmed; no actual injury proven. |
| Whether Belden’s transfer before the hearing prejudiced representation. | Belden could not represent himself adequately due to transfer. | Issue raised for first time on appeal; not addressed. | Not addressed on appeal due to lack of trial-court briefing. |
Key Cases Cited
- Bounds v. Smith, 430 U.S. 817 (U.S. 1977) (right to meaningful access requires adequate law libraries or assistance)
- Lewis v. Casey, 518 U.S. 343 (U.S. 1996) (actual injury requirement to access to courts)
- Phillips v. Ferguson, 182 F.3d 769 (10th Cir. 1999) (timeliness and viability of post-conviction relief claims)
- Taylor v. State, 74 P.3d 1236 (Wy. 2003) (statute-of-limitations for post-conviction relief; five-year limit)
- Oatts v. Jorgenson, 821 P.2d 108 (Wy. 1991) (avoids considering issues not raised in trial court)