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Craig Miles Goodwin, A/K/A Curtis Meyer v. Harold Carmel, Dr. Albert O. Singleton, Iii, M.D. Mary Lou Judiscak Lou Brothers Ken Tafoya

Citations: 107 F.3d 20; 1997 WL 43519; 1997 U.S. App. LEXIS 6872Docket: 96-1084

Court: Court of Appeals for the Tenth Circuit; February 3, 1997; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal by an individual, Craig Miles Goodwin, also known as Curtis Meyer, against a district court's summary judgment in favor of several defendants, including Harold Carmel and Dr. Albert O. Singleton III. The appeal centers on alleged civil rights violations due to denial of access to the courts, where Goodwin claims his legal materials were confiscated, he lacked access to legal mailing and research resources, and he received inadequate legal consultation. However, the district court found that Goodwin did not demonstrate any specific adverse consequences, such as missed deadlines or hindered legal actions, resulting from these alleged deprivations. The appellate court agreed with the lower court's findings, referencing the precedent in Lewis v. Casey, which requires showing actual injury for such claims to rise to a constitutional level. The appeal was decided without oral argument, and the judgment was affirmed, emphasizing that the order is not binding precedent and should only be cited under particular legal conditions.

Legal Issues Addressed

Application of Precedent from Lewis v. Casey

Application: The court applied the precedent set in Lewis v. Casey to assess whether the claims of impeded access to legal resources rose to a constitutional level.

Reasoning: The appeal was submitted without oral argument, and the court affirmed the district court's decision, agreeing with the magistrate judge's recommendations that Goodwin's claims were inconsequential and did not rise to a constitutional level, referencing the precedent set in Lewis v. Casey.

Denial of Access to Courts under Civil Rights Claims

Application: The court evaluated whether the plaintiff's allegations of confiscated legal materials and lack of legal research resources constituted a denial of access to the courts.

Reasoning: Goodwin asserts that his access was impeded because his legal materials were confiscated, he was unable to mail legal documents, he could not use legal books for research, and while he had consultations with a legal consultant, he was dissatisfied with that assistance and did not receive lawyer services.

Non-Binding Nature of Certain Judicial Orders

Application: The court noted that the order and judgment in this case are not binding precedent except under certain legal doctrines and discouraged citation unless specific conditions are met.

Reasoning: The order and judgment is not binding precedent except under certain legal doctrines, and the citation of such orders is generally discouraged unless specific conditions are met.

Requirement of Demonstrating Adverse Consequences

Application: The court determined that the plaintiff failed to demonstrate specific adverse consequences, such as missed filing deadlines, which is necessary to establish a denial of access to the courts.

Reasoning: However, the court found that Goodwin failed to demonstrate any specific adverse consequences resulting from these alleged deprivations, such as missing filing deadlines or being barred from pursuing legal actions.