Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-06-16

Docket: 1:19-cv-01591-EPG

The Ninth Circuit affirmed the district court’s judgments granting summary judgment to defendants on Jackson’s conspiracy and access-to-courts claims and granting judgment as a matter of law on his legal mail claim. The court applied de novo review to the summary judgment and judgment as a matter of law rulings, and abuse of discretion review to the decisions regarding preliminary injunctions, appointment of counsel, and motions in limine. Regarding the conspiracy claim, the court held that Jackson failed to state specific facts supporting the existence of an agreement or meeting of the minds among defendants to open his legal mail outside his presence. On the access-to-courts claim, the court found that Jackson offered only conclusory statements and failed to demonstrate “actual harm” in the form of past or imminent official interference with his presentation of claims to the courts. For the legal mail claim, the court determined that even construing Jackson’s pro se filings liberally, he provided no evidence sufficient for a reasonable juror to rule in his favor. The appellate court also affirmed the denial of Jackson’s motions for preliminary injunctions and appointment of counsel. The district court did not abuse its discretion in denying injunctive relief because Jackson had funds to pay for photocopies and failed to show irreparable harm or a likelihood of success on the merits regarding actual injury. Similarly, the court upheld the denial of counsel, finding that “exceptional circumstances” did not exist given Jackson’s demonstrated ability to articulate his claims pro se and the lack of likelihood of success. Finally, the affirmation included the district court’s grant of a motion in limine to exclude exhibits of opened envelopes, as Jackson failed to meet disclosure deadlines, prejudicing the defendants under Federal Rule of Civil Procedure 37(c)(1). As a result of this decision, the judgment in favor of the defendants is final and binding, and no further relief is available to Jackson on these claims.

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