Michael Wilson v. Donald Gaetz, 700 F. App'x 540

Michael S. Wilson, an Illinois inmate, sought law-library access in March 2012 to pursue family-court petitions against his ex-wife concerning parental contact with their son.
Law librarian Michelle Crews denied immediate access, explaining priority is given to criminal and civil-rights matters and saying she would try to fit him in if space opened; Wilson grieved and Warden Donald Gaetz denied the grievance.
Wilson obtained courthouse contact information and filing forms from Crews the following month but was again told of the library’s priorities.
Wilson filed two petitions in state court (one in June 2012 and another in February 2013) requesting relief and a writ to secure his presence; the record shows the state court did not issue a writ compelling his attendance.
Wilson sued Gaetz and Crews under 42 U.S.C. § 1983 alleging denial of his First Amendment right of access to the courts for family-law matters and failure to transport him to a hearing.
The district court granted summary judgment to defendants on qualified-immunity grounds; the Seventh Circuit affirmed, concluding Wilson could not show that lack of library access caused the denial of a nonfrivolous legal claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did denial of law-library access for family-law matters violate right of access to courts?	Wilson: access right covers family-law claims; denial prevented meaningful access.	Crews/Gaetz: no clearly established right to library assistance for family-law matters; priority to criminal and civil-rights is permissible.	Court assumed arguendo right existed but found no injury; summary judgment affirmed.
Must officials be present/transport inmate to family-court hearings?	Wilson: had right to be present for hearings and to obtain writ to secure attendance.	Defendants: no writ issued; administrators did not prevent seeking relief.	No evidence defendants prevented access or attendance; no violation shown.
Was qualified immunity available to defendants?	Wilson: officials violated clearly established rights.	Defendants: any right was not clearly established; reasonable officials acted within policies.	Qualified immunity not dispositive because plaintiffs failed to show actual injury; judgment for defendants affirmed.
Did Wilson demonstrate actual injury to a nonfrivolous claim (Christopher test)?	Wilson: inability to use library impeded his petitions and pursuit of remedies.	Defendants: Wilson nonetheless filed state petitions and sought writs; record shows no obstruction.	Wilson could not show that library denial caused loss of a nonfrivolous claim; summary judgment proper.

Pearson v. Callahan, 555 U.S. 223 (qualified-immunity framework)
Harlow v. Fitzgerald, 457 U.S. 800 (objective qualified-immunity standard)
Lewis v. Casey, 518 U.S. 343 (prisoners' right of access to courts requires tools to challenge sentence/conditions)
Bounds v. Smith, 430 U.S. 817 (access-to-courts requirement for prisons)
Christopher v. Harbury, 536 U.S. 403 (actual-injury requirement for access-to-courts claims)
Gill v. City of Milwaukee, 850 F.3d 335 (Seventh Circuit qualified-immunity analysis)
Bridges v. Gilbert, 557 F.3d 541 (scope of access-to-courts protections)
Snyder v. Nolen, 380 F.3d 279 (prisoners' right to file nonfrivolous civil actions)
Ortiz v. Downey, 561 F.3d 664 (application of Christopher injury standard)
Antonelli v. Sheahan, 81 F.3d 1422 (denial of access requires showing of prejudice to a nonfrivolous claim)