Eckard v. Leopold, 2:19-cv-00816

Plaintiff Gabriel Eckard, a pretrial detainee at Snohomish County Jail, alleges defendants John Leopold (classification specialist) and Kimberly Parker (classification supervisor) sanctioned him by denying law-library access April 1–15, 2019 for a jail-rule violation.
Eckard claims the sanction violated his constitutional right of access to the courts and interfered with his right to self-representation in his pending state criminal case.
He seeks a permanent injunction barring future library bans and $1,000,000 in compensatory and $1,000,000 in punitive damages.
The magistrate judge screened the pro se § 1983 complaint under 28 U.S.C. § 1915A and concluded Eckard failed to allege actual injury from the temporary restriction.
Court noted Eckard filed numerous civil suits both before and after the sanction period, undermining any claim that the two-week restriction frustrated nonfrivolous litigation.
The judge also concluded federal intervention into Eckard’s claim about self-representation would improperly interfere with ongoing state criminal proceedings under Younger abstention.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether two-week denial of law-library access violated right of access to courts	Eckard: library ban denied access and thereby injured his ability to litigate	Defendants: temporary sanction did not cause an actual injury to Eckard’s ability to pursue nonfrivolous claims	Denied — plaintiff failed to allege or show actual injury; access claim dismissed with prejudice
Whether federal court may adjudicate claim that sanction impaired Eckard’s right to self-representation in pending state criminal case	Eckard: sanction and jail practices obstruct his right to represent himself in state prosecution	Defendants: federal court must not interfere with ongoing state criminal proceedings; state forum is available	Dismissed under Younger abstention — federal court abstains from intruding into ongoing state criminal matter

Bounds v. Smith, 430 U.S. 817 (1977) (prisoners have a constitutional right of access to the courts requiring either an adequate law library or legal assistance)
Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claim requires showing of actual injury to nonfrivolous litigation)
Younger v. Harris, 401 U.S. 37 (1971) (federal courts must refrain from interfering with ongoing state criminal prosecutions absent extraordinary circumstances)
Christopher v. Harbury, 536 U.S. 403 (2002) (clarifies actual-injury requirement for access-to-courts claims and connection to underlying claim)
Columbia Basin Apartment Ass’n v. City of Pasco, 268 F.3d 791 (9th Cir. 2001) (articulates Ninth Circuit application of Younger abstention factors)