Douglas Juiffre v. Broward Sheriff's Office, 16-15818

Plaintiff Douglas Juiffre, a pro se inmate formerly at Paul Rein Detention Facility, sued under 42 U.S.C. § 1983 alleging denial of access to the courts based on the jail’s legal-research procedures.
The facility required inmates to submit an Inmate Law Library Request Form limiting them to requesting four cases per week by exact citation; inmates could not browse a physical law library.
Juiffre claimed the citation-only system hindered his ability to research and caused the dismissal of a prior 2015 access-to-courts case.
A magistrate judge recommended dismissal under 28 U.S.C. § 1915(e)(2)(B)(ii) for failure to state a claim, finding Juiffre had not shown the required actual injury.
The district court adopted the R&R and dismissed the complaint; Juiffre appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Juiffre pleaded the "actual injury" required for an access-to-courts claim	Juiffre: the jail’s exact-cite system prevented proper legal research and caused dismissal of his earlier case, showing actual injury	Defendants: Juiffre did not show any specific, nonfrivolous claim was hindered or that the library restrictions caused an actionable injury	Court: Dismissal affirmed — Juiffre failed to allege actual injury and thus failed to state a claim
Whether Juiffre can rely on the dismissal of his 2015 access claim as evidence of actual injury	Juiffre: the prior dismissal reflects the harm caused by the library system	Defendants: the 2015 dismissal did not establish actual injury; plaintiff cannot bootstrap one deficient access claim to prove another	Court: The 2015 dismissal does not satisfy the actual-injury requirement; appeal fails

Bounds v. Smith, 430 U.S. 817 (1977) (prisoners must have adequate law libraries or assistance to prepare meaningful legal papers)
Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claims require showing of actual injury to nonfrivolous cases)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleadings must include factual allegations sufficient to state a plausible claim)
Mitchell v. Farcass, 112 F.3d 1483 (11th Cir. 1997) (Section 1915 screening standard tracks Rule 12(b)(6))
Wilson v. Blankenship, 163 F.3d 1284 (11th Cir. 1998) (scope of actionable access-to-courts claims and actual-injury requirement)
Tannenbaum v. United States, 148 F.3d 1262 (11th Cir. 1998) (pro se pleadings receive liberal construction)
Leal v. Georgia Dept. of Corrections, 254 F.3d 1276 (11th Cir. 2001) (issues not raised below generally are not considered on appeal)