Cape v. LaGrange County Sheriffs Department/County Jail, 1:17-cv-00375

Plaintiff Daniel Cape, a pro se prisoner, sued the LaGrange County Sheriff’s Department/County Jail alleging the jail has an inadequate law library.
The case was removed to federal court because it raised a federal claim under 42 U.S.C. § 1983.
The court screened the complaint under 28 U.S.C. § 1915A to determine whether it states a cognizable claim.
Cape did not allege that jail actions prevented him from filing a complaint or appeal, nor did he identify any actual, concrete injury to his litigation efforts.
The court held that a subpar law library alone does not establish a denial of access to the courts absent actual injury to pursue a nonfrivolous claim.
The court allowed Cape leave to amend and directed the clerk to send him a prisoner complaint form; it warned that failure to amend by the deadline would result in dismissal under § 1915A.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether inadequate law library states a § 1983 denial-of-access claim	Cape alleges the jail’s law library is inadequate	Implicit defense: no actionable injury shown	Dismisses for failure to state a claim absent actual injury
What showing is required for access-to-courts claim	Cape seeks relief based on library inadequacy	State must only provide ability to file complaints/appeals, not ensure effective litigation	Court applies Lewis standard: must allege hindered ability to pursue nonfrivolous claim and concrete injury
Procedural disposition	Cape seeks to proceed on current complaint	Court can sua sponte screen and dismiss under § 1915A	Court gives leave to amend and sets deadline; warns of dismissal if no amendment
Pleading standard for pro se prisoner	Cape proceeds pro se so complaint construed liberally	Court still applies § 1915A screening and legal standards	Liberal construction allowed but legal deficiency not excused; must allege facts showing actual injury

Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints are construed liberally)
Savory v. Lyons, 469 F.3d 667 (7th Cir. 2006) (elements of a § 1983 claim)
Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claim requires showing state action hindered pursuit of a nonfrivolous claim and concrete injury)
May v. Sheahan, 226 F.3d 876 (7th Cir. 2000) (same standard for actual injury in access claims)
Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (right of access protects ability to file, not effective litigation)
Luevano v. Wal-Mart, 722 F.3d 1014 (7th Cir. 2013) (leave to amend and standards for pleading)