A prisoner sued the staff at his jail, alleging they deprived him of the ability to research evidentiary and court rules ahead of and during his civil trial. The District Court dismissed the complaint, and the Third Circuit affirmed. Both courts found that the defendants were entitled to qualified immunity because, at the time of the alleged violation, a prisoner had no clearly established right to access legal materials at the trial stage of a civil case. The Third Circuit noted that such a right exists now.

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