When a man believes he is unlawfully held or illegally convicted, he should prepare a brief or state his complaint in letter form and address it to his lawyer or a judge.

[3] Specifically, Cochran v. Kansas ruled in favor of a petitioner, who was a prisoner, who wished to file with the federal courts a writ of habeas corpus.

In the case of Bounds v. Smith, respondents of the courts are those incarcerated within the Division of Prisons of the North Carolina Department of Correction.

These respondents filed three actions alleging a violation of their Fourteenth Amendment[6] rights through denial of proper avenues to research.

The courts approved the motion based on a number of valid claims made by the respondents, specifically citing the lack of an adequate prison library system reason enough for a trial.

Due to precedent established in, first, Johnson v. Avery, and then Younger v. Gilmore, the courts found that equality under law had been disregarded because of a severe lack of assistance for inmates wishing to prepare legal documents.

Specifically in the case of North Carolina's prison system however, the substance of valuable legal assistance was scarce and thus presented a possibly more logistical problem than argued by the respondents.

The District Court ruled that North Carolina must develop and institute a plan that provided inmates with a form of legal assistance that satisfied a degree of Constitutionality.

It was suggested to Senators that they create an effective and economic plan possibly providing lawyers and other legal professionals along with the expansion of state law libraries.

Protestors of the new plan claimed it was inadequate in that it failed to satisfy the basic legal needs of every prisoner, thus denying citizens access to the courts.

With the approval of the plan, the State then applied for federal aid, hoping to cover up to 90% of the costs of building and maintaining the new prison libraries.

Rather, it ordered petitioners themselves to devise a remedy for the violation, strongly suggesting that it would prefer a plan providing trained legal advisors.

Justice Scalia, writing for the court, stated: "In other words, Bounds does not guarantee inmates the wherewithal to transform themselves into litigating engines capable of filing everything from shareholder derivative actions to slip-and-fall claims.