Plaintiff, Robert DeMallory, is an inmate at Wisconsin’s Waupun Correctional Institute (WCI). On August 17, 1978, WCI authorities placed DeMallory in the WCI Adjustment Center, a maximum security facility within the prison that separates certain inmates from general population inmates, because of his alleged involvement in a disturbance at WCI. The Adjustment Center’s surroundings are spartan, and its prisoners’ activities are more restricted than those of general population inmates. On November 4, 1978, prison authorities released DeMallory from the Adjustment Center, but returned him on January 10, 1979, where he remained until February, 1988.
DeMallory originally brought two suits. In the first, DeMallory alleged that conditions of confinement in the WCI Adjustment Center amounted to cruel and unusual punishment. In the second, he argued that limitations on the legal resources available to Adjustment Center prisoners unconstitutionally restrict their access to the courts, thus violating their Fourteenth Amendment rights. Defendants, various government and prison officials, moved for summary judgment on both the eonditions-of-confinement claim and the access-to-courts claim. DeMallory moved for summary judgment on the access-to-courts claim. After submitting the matter to a magistrate, the district court granted summary judgment on both of DeMallory’s claims in favor of defendants. DeMallory appeals.
I.
DeMallory first argues that conditions in the Adjustment Center constitute cruel and unusual punishment. His Eighth Amendment claim focuses primarily on the defendants’ allegedly willful failure to protect him from the activities of other Adjustment Center inmates and the unsanitary conditions in the unit. He alleges that WCI officials knowingly housed mentally-ill inmates with the rest of the Adjustment Center population, that these inmates soil their cells and surrounding areas by throwing food, human waste, and other debris, and that these inmates have set “approximately 50 fires,” that have resulted in the hospitalization of several inmates, including himself. He further alleges that the various defendants are personally responsible for the health and safety hazards, specifically, that WCI officials intentionally allowed the Adjustment Center to remain unsanitary and kept Adjustment Center windows locked despite repeated fires. Finally, De-Mallory contends that a guard spit on him while he was housed in the Adjustment Center.
The district court granted summary judgment in favor of the defendants, holding that “there has been no competent evidence presented that the prison officials evidenced a deliberate indifference to DeMallory’s medical needs, due to the inhalation of smoke, for a finding that his Eighth Amendment rights were violated.” As for the spitting incident, the court ruled that “a correctional officer spitting upon a prisoner does not rise to the level of a constitutional violation.” Id. at 3. We agree with the district court’s disposition of those portions of DeMallory’s Eighth Amendment claim that address the medical care given DeMallory and the spitting incident.
*445Because the district court failed to address the primary thrust of DeMallo-ry’s complaint—that WCI officials have willfully allowed unsanitary and dangerous conditions to continue in the Adjustment Center, however, we reverse the order granting summary judgment and remand for further proceedings. “It has long been established that prisoners have rights under the Eighth Amendment to receive reasonable protection from harm inflicted by other inmates.” Madyun v. Thompson, 657 F.2d 868, 875 (7th Cir.1981). Such a claim may be sustained only by a showing of deliberate indifference by prison officials; mere negligence is not enough. Duckworth v. Franzen, 780 F.2d 645, 652-55 (7th Cir.1985), cert. denied, 479 U.S. 816, 107 S.Ct. 71, 93 L.Ed.2d 28 (1986). Liability under the Eighth Amendment “requires, at a minimum, that the prison officials have realized there was imminent danger and have refused—consciously refused, knowingly refused—to do anything about it.” Campbell v. Greer, 831 F.2d 700, 702 (7th Cir.1987).
The district court, without expressly saying so, apparently treated the defendants’ motion for summary judgment on DeMallo-ry’s Eighth Amendment claim as a motion to dismiss pursuant to Fed.R.Civ.P. 12(b)(6). Only the plaintiff’s complaint and the defendants’ answers were before the court; no discovery was taken. In their answer to the complaint, the defendants asserted that they had insufficient information from which they could form an opinion with respect to the allegations and denied any unconstitutional conduct. By awarding summary judgment in this situation, the district court actually dismissed the case on the pleadings. In so doing, the district court failed to follow the basic standard governing Rule 12(b)(6) dismissals.
“[A] complaint should not be dismissed for failure to state a claim unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.” Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 101-02, 2 L.Ed.2d 80 (1957). Moreover, in “complex cases involving both fundamental rights and important questions of public policy, such peremptory treatment is rarely appropriate.” Rutan v. Republican Party of Illinois, 848 F.2d 1396, 1414 (7th Cir., 1988) (Ripple, J., concurring in part, dissenting in part). In this case, the district court did not read DeMallory’s Eighth Amendment claim in this light. Rather, by focusing on only two incidents alleged in the complaint, the court failed to consider the complaint as a whole and seemingly ignored the more pressing issues alleged by DeMallory.
DeMallory’s conditions-of-confinement complaint, taken as true, as it must for purposes of a motion to dismiss, states a claim on which relief can be granted. The Supreme Court has emphasized that “[n]o static ‘test’ can exist by which courts determine whether conditions of confinement are cruel and unusual, for the Eighth Amendment ‘must draw its meáning from the evolving standards of decency that mark the progress of a maturing society.’ ” Rhodes v. Chapman, 452 U.S. 337, 346, 101 S.Ct. 2392, 2399, 69 L.Ed.2d 59 (1981) (citation omitted). See also Smith v. Fairman, 690 F.2d 122, 125 (7th Cir.1982), cert. denied, 461 U.S. 946, 103 S.Ct. 2125, 77 L.Ed.2d 1304 (1983). In all cases, the determination as to whether prison conditions constitute cruel and unusual punishment turns on the totality of the conditions of confinement. Madyun, 657 F.2d at 874; see also Smith, 690 F.2d at 125 (quoting Madyun). Not surprisingly, suits challenging the sanitation and safety of prisons have received varying treatment by federal courts. This court has repeatedly stressed that the Eighth Amendment requires prison officials to maintain minimal sanitary and safe prison conditions and we have not hesitated to award damages to inmates when prison conditions have fallen below the threshold of decency ensured by the Eighth Amendment. See, e.g., Davenport v. DeRobertis, 844 F.2d 1310 (7th Cir.1988) (Eighth Amendment requires at least five hours of exercise and one shower each week for inmates segregated more than ninety days); Wells v. Franzen, 777 F.2d 1258 (7th Cir.1985) (Eighth Amendment requires minimal exercise, showers, clothing, and *446sanitary eating conditions). We therefore reverse the judgment of the district court and remand the case for further consideration.
II.
DeMallory next argues that restrictions on library access for prisoners in the Adjustment Center preclude their effective access to the courts. Prisoners in the Adjustment Center may not go to the prison library, may not confer personally with WCI’s inmate paralegals, and may not participate in the legal training and services offered through the WCI paralegal program. The Adjustment Center prisoners may check out books from the legal library by written request and may consult paralegals by correspondence. They also may confer with each other during exercise periods and seek some legal assistance through public defenders, court-appointed counsel, private attorneys, or Wisconsin’s Legal Assistance to Institutionalized Persons (LAIP) Program. A set of 1969 Wisconsin statutes is also available to the inmates housed in the Adjustment Center. The record includes several memoranda in which WCI officials acknowledge that they are “aware of the problem of legal assistance for those inmates in segregation status,” but no solution appears forthcoming.
A prison inmate’s right of access to the courts is the most fundamental right he or she holds. “All other rights of an inmate are illusory without it, being entirely dependent for their existence on the whim or caprice of the prison warden.” Adams v. Carlson, 488 F.2d 619, 630 (7th Cir.1973). In Bounds v. Smith, 430 U.S. 817, 97 S.Ct. 1491, 52 L.Ed.2d 72 (1977), the Supreme Court held that the constitutional right of access to the courts “requires prison authorities to assist inmates in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law.” Id., at 828, 97 S.Ct. at 1498. Prison authorities need not provide both of these, but must provide one or the other, or a comparable alternative. Id. at 830-32, 97 S.Ct. at 1499-1500. Prison officials bear an affirmative duty to provide inmates with this reasonable access to courts and counsel and also bear the burden of proving the adequacy of the means they provide. Campbell v. Miller, 787 F.2d 217, 225-26 (7th Cir.), cert. denied, 479 U.S. 1019, 107 S.Ct. 673, 93 L.Ed.2d 724 (1986). The defendants, therefore, can prevail if they can demonstrate that DeMallo-ry had access to an adequate library or to adequate personal legal assistance.
The magistrate found that although the legal assistance available to the Adjustment Center’s prisoners might not be “optimal,” it constituted “sufficient access to the courts according to Bounds.” The district court agreed. We disagree. The district court lacked the evidentiary basis necessary for granting the defendants’ summary judgment. DeMallory contends that the procedures available to inmates at the Adjustment Center fail both elements of this test. He argues first that the law library available to Adjustment Center inmates is inadequate. As noted, prison authorities denied DeMallory all access to the library with the exception of 1969 Wisconsin Statutes housed in the Adjustment Center and specific volumes requested by inmates. In Corgain v. Miller, 708 F.2d 1241 (7th Cir.1983), this court held a system functionally similar to WCI’s constitutionally inadequate. In Corgain, inmates challenged the adequacy of their access to state courts while they were incarcerated at the United States Penitentiary at Marion, Illinois. The Marion law library was deficient in state law materials, but the inmates could obtain copies of necessary materials by written request accompanied by precise citations. We agreed with a federal magistrate’s conclusion that Marion’s system was constitutionally insufficient.
The magistrate correctly concluded that the law library system at USP-Marion, without state law materials or supplemental legal aid, was inadequate. He aptly characterized the Shawnee Library System’s requirement for precise citations for photocopying as a “Catch 22” because the inmate could obtain precise *447citations only if he could refer to state law materials.
Id. at 1250. We then approved plans submitted by prison officials to remedy the inadequate access by providing inmates either with starter libraries, in which the inmates themselves could do preliminary research, or with lists of legal services offices with whom the state had contracted to provide assistance to inmates. See id. at 1248-51.
We again addressed the access-to-courts issue in Caldwell v. Miller, 790 F.2d 589 (7th Cir.1986). In Caldwell, prisoners at Marion challenged restrictions placed on library access following a “lockdown” imposed after the death of an inmate and two guards. During the lockdown, prisoners were denied access to the main library, but were allowed to initiate legal research in smaller “basic libraries” and to request copies of further materials by written requests including exact page citations. The district court granted summary judgment in favor of the defendant warden. We reversed, holding that factual issues remained regarding the sufficiency of the materials available in the basic libraries. The court noted that if “the exact-cite system is supplemented by adequate reference materials in the basic library,” then the exact-cite system may be permissible. Id. at 607. Thus, the mere existence of basic libraries did not preclude the inmates from raising a factual issue regarding the sufficiency of their access to the courts. Id. at 607. In the Campbell case, however, we upheld the sufficiency of the “exact-cite” system for inmates in a segregated control unit based upon the evidentiary record before the district court. We found this system adequate in that case because the control unit library “is designed to facilitate the initial steps of legal research, viz., the formulation of tentative theories and the notation of materials needed to be consulted,” Campbell, 787 F.2d at 227, and because the “exact-cite” system did not engender any delays. Id. at 229.1
DeMallory, however, had no access to law libraries—even “starter” or “basic” libraries. Unlike the control unit in Campbell, the Adjustment Center library lacked the primary resources to allow DeMallory or other inmates to adequately begin their initial legal research or to formulate tentative theories.2 Moreover, because the district court was unable to appoint an attorney to represent him, DeMallory had to proceed without counsel. DeMallory’s meaningful access to the courts, therefore, rested solely on written correspondence with inmate paralegals for assistance on his Eighth Amendment claim. Dependence on untrained inmate paralegals as an alternative to library access does not provide constitutionally sufficient access to the courts. “Rather, when inmates have no access to a law library they must be provided with assistance by trained, skilled, and independent legal personnel.” Walters v. Thompson, 615 F.Supp. 330, 340 (N.D.Ill.1985).3
*448The defendants justify the restrictions on DeMallory’s access to legal assistance on the grounds that he and other inmates in the Adjustment Center are security risks. Generalized security concerns, however, are insufficient to support such a ban. Instead, prison officials must come forward with evidence that the specific contact at issue threatens security and must show that less restrictive measures, such as precounseling searches, are not possible. See, e.g., Turner v. Safly, — U.S. -, 107 S.Ct. 2254, 2262, 96 L.Ed.2d 64 (1987); Kunzelman v. Thompson, 799 F.2d 1172, 1179 (7th Cir.1986); Campbell, 787 F.2d at 225-26. WCI officials have done neither. Moreover, several genuine issues of material fact remain relating to less-restrictive measures, which precludes awarding summary judgment for the defendants at this stage. The defendants argue that DeMallory has “meaningful” access to legal assistance through the aid of LAIP lawyers, the State Public Defender’s Office, and the private bar. DeMallo-ry, however, contests this position and contends that although LAIP provides a variety of legal assistance to inmates, it does not handle conditions-of-confinement or institutional-discipline cases like his. The record also is unclear as to the availability of the Public Defender and private attorneys in assisting plaintiffs like DeMallory. In addition, a dispute exists as to whether the inmate paralegals provide an adequate substitute for counsel and whether the State can provide greater direct access to paralegals. The State argues that direct contact between inmates and paralegals would overtax prison resources because of the security risk involved in permitting paralegals into the segregated Adjustment Center. Yet the record reflects that, at least in some other limited circumstances, general population inmates were allowed into the Adjustment Center under the supervision of prison officials. A genuine dispute exists as to whether similar arrangements can be made to allow Adjustment Center inmates, like DeMallory, to confer with the prison paralegals without overburdening the prison authorities. The district court, then, erroneously concluded that the State provided DeMallory with meaningful access to the courts. Before entering judgment, it is necessary for the district court to hold a hearing to resolve these issues and to determine whether the State’s legitimate security concerns justify the restrictions on DeMallory’s access to legal assistance.
As an alternative basis for its decision, however, the district court held that DeMallory had failed to show prejudice and therefore failed to state a claim on which relief could be granted. Because the district court apparently misperceived the nature of the prejudice requirement, we decline to accept its conclusion. We recently emphasized that the necessary showing of prejudice is a minimal one. Hossman v. Spradlin, 812 F.2d 1019, 1022 (7th Cir.1987). We require only that the plaintiff “articulate, to some degree, the basis for his claim that his access to the courts was significantly ... impaired.” Id. at 1022. DeMallory’s complaint clearly alleges that the WCI rules prevent adequate legal research and counseling. Such a complaint amounts to a sufficient allegation of prejudice to state a claim on which relief can be granted. Cf. Walters v. Thompson, 615 F.Supp. at 338 (similar complaint sufficient to support preliminary injunction).
Generally, we have required a showing of prejudice only where minor or indirect limitations on access to courts are alleged. Where, as here, the plaintiff alleges a direct and continuous limitation on access to legal materials or counsel, we have required no such showing. Compare Hossman, 812 F.2d at 1021-22 (occasional interference with library access and destruction *449of unspecified court papers—showing of prejudice required); Jones v. Franzen, 697 F.2d 801 (7th Cir.1983) (limits on number of free photocopies—showing of prejudice required); Bach v. Coughlin, 508 F.2d 303 (7th Cir.1974) (postage regulations—showing of prejudice required); and Isaac v. Jones, 529 F.Supp. 175 (N.D.Ill.1981) (denial of library access on one occasion—showing of prejudice required); with Caldwell, 790 F.2d 589 (continuous limitation on library access—no discussion of prejudice); Campbell, 787 F.2d at 217 (continuous limitation on library access—no discussion of prejudice); and Corgain, 708 F.2d at 1241 (continuous limitation on library access—no discussion of prejudice); see also Walters, 615 F.Supp, at 338 (criticizing requirement of showing prejudice). In our adversary legal system, few things can be as prejudicial as the denial of basic legal resources. In essence, when an inmate complains of prison rules that substantially and continuously limit his or her access to legal materials and counseling, the complaint carries an inherent allegation of prejudice.
Furthermore, the record before us shows evidence of prejudice. Even WCI officials have repeatedly admitted that current rules create a “problem of legal assistance” for Adjustment Center inmates. In addition, DeMallory’s reply brief in the conditions-of-confinement action was filed too late for the magistrate’s consideration. Where limitations on library use prevent filing of briefs in time for the court’s consideration, those limitations are sufficiently prejudicial to sustain an access-to-courts claim. See Isaac, 529 F.Supp. at 178-79 (by implication). We therefore find that DeMallory has shown sufficient prejudice to support his access-to-courts claim.
For the reasons stated, we reverse in part and remand for further proceedings consistent with this opinion.4
. Corgain, Campbell, and Caldwell addressed challenges mounted by prisoners at the United States Penitentiary at Marion, Illinois, and Campbell addressed court access by prisoners in Marion’s Control Unit. “Marion is the highest level maximum security prison in the federal penitentiary system. The Control Unit is designated for those inmates deemed unfit for the general population at Marion because they pose a threat to others or to the orderly operation of the institution." Campbell, 787 F.2d at 220. Thus, “Marion presents unique disciplinary and security considerations. This is true whether one is dealing with general population inmates or with those in the Control Unit.” Caldwell, 790 F.2d at 606. By contrast, although WCI is a maximum security facility, its security concerns are generally less severe than those present at Marion. Therefore, WCI's legitimate security needs, without more, do not justify restrictions more severe than those tested in Corgain, Caldwell, and Campbell.
. The record also is unclear as to whether the “volume-cite" system in place at the Adjustment Center caused unreasonable delays in filing court documents.
. Other courts facing this issue also have taken the position that, at a minimum, inmates either must be given direct access to adequate libraries or must receive help from trained and competent legal personnel other than mere "writ writers" or inmate paralegals. See, e.g., Harrington v. Holshouser, 741 F.2d 66, 69-70 (4th Cir.1984) (limited library access with help from untrained inmate paralegals insufficient); Ramos v. Lamm, 639 F.2d 559, 584-85 (10th Cir.1980) *448(access to untrained inmate paralegals insufficient), cert. denied, 450 U.S. 1041, 101 S.Ct. 1759, 68 L.Ed.2d 239 (1981); Kendrick v. Bland, 586 F.Supp. 1536, 1552 (W.D.Ky.1984) (telephonic communication with untrained inmate paralegals insufficient for prisoners without library access); Canterino v. Wilson, 562 F.Supp. 106, 110-12 (W.D.Ky.1983) (inmates without library access must be given access to legally-trained personnel). Cf. Lovell v. Brennan, 566 F.Supp. 672, 696 (D.Me.1983) (direct counseling by inmate advocate and hiring of full-time advocate for segregated prisoners sufficient), aff’d, 728 F.2d 560 (1st Cir.1984).
. The defendants, for the first time on appeal, argue that they are entitled to immunity. Although we have doubts as to the applicability of qualified immunity to the defendants’ conduct in this case, we do not decide the issue because the defendants waived this argument by failing to raise it before the district court. Textile Banking Co., Inc. v. Rentschler, 657 F.2d 844, (7th Cir.1981).