U.S. appeals court: smoke.

• Position: Medical Care - Brief Article

Lehn v. Holmes, 364 F.3d 862 (7th Cir. 2004). A pro se state prisoner sued a state, alleging denial of access to the courts and living conditions that violated the Eighth Amendment. The district court dismissed the action and the prisoner appealed. The appeals court reversed and remanded. The appeals court held that the State of Illinois, the state in which the prisoner was confined, was the proper defendant on the prisoner's claim that denial of access to Maryland legal materials hampered his ability to respond to pending Maryland criminal charges. The court also found that the prisoner had standing to challenge the corrections department's system-wide practice of...