IN BOUNDS V. SMITH, NORTH CAROLINA PRISONERS FILED A SECTION 1983 ACTION AGAINST THE STATE CLAIMING THAT THE LACK OF LEGAL RESEARCH FACILITIES IN THE PRISONS VIOLATED THE INMATES' RIGHT OF ACCESS TO THE COURTS. THE U.S. SUPREME COURT UPHELD THE PRISONERS' CASE AND MANDATED STATES TO PROVIDED LAW LIBRARIES OR SATISFACTORY ALTERNATIVES FOR THE USE OF INMATES WHO WISH TO PETITION THE COURTS. THE FIRST PORTION OF THIS CASE NOTE EXAMINES THE GROWTH OF THE DOCTRINE OF THE PRISONER'S ACCESS TO THE COURTS. GENERALLY, EX PARTE HULL (1941) IS CITED AS THE FIRST STATEMENT OF A PRISONER'S RIGHT TO ACCESS TO THE FEDERAL COURTS. THIS CASE MERELY STATED THAT THE STATE MUST PROVIDE NOTARY SERVICES AND MAIL THE PRISONER'S PETITION. GRADUALLY DECISIONS HAVE UPHELD THE WORK OF 'JAILHOUSE LAWYERS' AND HAVE DIRECTED STATES NOT TO INTERFERE WHEN PRISONERS ATTEMPT TO FILE CIVIL SUITS (SPECIFICALLY, A DIVORCE ACTION). HOWEVER, THE BOUNDS CASE GOES FAR BEYOND PREVIOUS DECISIONS IN THAT IT ORDERS STATES TO ACTIVELY ASSIST BY PROVIDING LAW LIBRARIES OR OTHER LEGAL SERVICES. THE AUTHORITY OF THE FEDERAL COURTS TO ORDER SUCH ASSISTANCE IS COMMENTED UPON WITH NUMEROUS CITATIONS SUPPORTING BOTH SIDES OF THE ARGUMENT. IT IS CONCLUDED THAT THE TERMS 'ADEQUATE' LAW LIBRARIES AND 'MEANINGFUL' ACCESS TO THE COURTS ARE AMBIGUOUS AND WILL HAVE TO BE SETTLED THROUGH FURTHER DECISIONS. IT IS ALSO CONCLUDED THAT THE DECISION MANDATES THE ESTABLISHMENT OF PRISON LAW LIBRARIES BECAUSE THE ADEQUACY OF ALTERNATIVES HAS NOT YET BEEN ESTABLISHED. THE 238 FOOTNOTES CONTAIN EXTENSIVE REFERENCES. (GLR)