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P1470 Courts have an obligation to ensure that an indigent prisoner's incarceration does not interfere with his/her right to pursue civil litigation in the face of bona fide threats to the prisoner's personal or property interests; summary judgment entered without opposition against a prisoner plaintiff who was nine minutes late for a telephonic appearance from prison was reversed and remanded with directions to determine whether the plaintiff is indigent and faces a bona fide threat to his personal or property interests, and, if so, to consider what remedies are available to protect his right of meaningful access.CitationAPOLLO v GYAAMI (Prison Walls) 167 CA4 1468 [See: PenC 2601; Wantuch v Davis 32 CA4 786, T/AT 3/95]
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