dissenting.
In Knop v. Johnson, 977 F.2d 996, 999 (6th Cir.1992), an earlier appeal in this *407case, we determined that “we are satisfied that there are at least some Michigan prisoners who have been denied the type of access to the courts required under current Supreme Court doctrine.” (Emphasis added.) The underpinning for this conclusion was the Supreme Court’s decision in Bounds v. Smith, 430 U.S. 817, 97 S.Ct. 1491, 52 L.Ed.2d 72 (1977).
Recently, the Supreme Court has revisited Bounds and considerably narrowed its holding. Lewis v. Casey, 518 U.S. 343, 116 S.Ct. 2174, 135 L.Ed.2d 606 (1996) (because Bounds did not create an abstract free-standing right to a law library or legal assistance, an inmate cannot establish relevant actual injury simply by establishing that his prison’s law library or legal assistance program is sub-par in some theoretical sense).1
In recognition of the narrowing of Bounds by Lewis, the court in this appeal concludes that the Lewis “ ‘actual injury’ requirement does differ from the one used by this court[J” Since in Knop we did conclude that entitlement to a remedy had been established, this statement can only mean that Lewis requires us to now repudiate the conclusion reached in Knop. On this point, I am in complete agreement with the court. Where I part company with the majority, however, is in the ordering of a remand to allow the plaintiffs another opportunity to establish “actual injury.”
The defendants have advanced a proposal that is designed to provide meaningful access to the courts. In response, the plaintiffs have done exactly what Lewis says they cannot do.
Although Bounds itself made no mention of an actual-injury requirement, it can hardly be thought to have eliminated that constitutional prerequisite. And actual injury is apparent on the face of almost all the opinions in the 35-year line of access-to-courts cases on which Bounds relied. Moreover, the assumption of an actual-injury requirement seems to us implicit in the opinion’s statement that “we encourage local experimentation” in various methods of assuring access to the courts. One such experiment, for example, might replace libraries with some minimal access to legal advice and a system of court-provided forms such as those that contained the original complaints in two of the more significant inmate-initiated cases in recent years, Sandin v. Conner, 515 U.S. 472, 115 S.Ct. 2293, 132 L.Ed.2d 418 (1995); and Hudson v. McMillian, 503 U.S. 1, 112 S.Ct. 995, 117 L.Ed.2d 156 (1992) — forms that asked the inmates to provide only the facts and not to attempt any legal analysis. We hardly think that what we meant by “experimenting” mth such an alternative was simply announcing it, whereupon suit would immediately lie to declare it theoretically inadequate and bring the experiment to a close. We think we envisioned, instead, that the new program would remain in place at least until some inmate could demonstrate that a nonfriv-olous legal claim had been frustrated or was being impeded.
116 S.Ct. at 2180-81 (citations and footnotes omitted) (emphasis added).
Additionally, the court makes only a passing reference to the Prison Litigation Reform Act (PLRA or Act), 18 U.S.C. § 3626. The Act is not factored into the analysis. The PLRA, which was intended to limit judicial involvement in prison administration, limited prospective relief in prison conditions cases to relief that was
no further than necessary to correct the violation of the Federal right of a particular plaintiff or plaintiffs. The court shall not grant or approve any prospective relief unless the court finds that *408such relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right. The court shall give substantial weight to any adverse impact on public safety or the operation of a criminal justice system caused by the relief.
Id. § 3626(a)(1)(A).
In my view, when Lewis and the PLRA are read together, they dictate a result different than that reached by the court. I would remand and order a dissolution of the temporary injunction and dismissal of this action, conditioned upon the state putting into effect the remedial plan it offered to the court. After that has been accomplished, if an individual inmate feels he or she can establish a denial of the right to present a non-frivolous claim to a court of competent jurisdiction, a new individual action may be brought.2 On access to court claims, class actions will generally not be a suitable vehicle for bringing suit due to the highly individualized nature of the proof of an “actual injury.”3
. Justice Thomas stated in his concurring opinion: "And though we have not overruled Bounds, we have undoubtedly repudiated its reasoning in our consistent rejection of the proposition that the States must provide counsel beyond the trial and first appeal as of right.” 116 S.Ct. at 2195.
. As Lewis makes clear, it is not just any alleged denial of access that will trigger a constitutional violation claim:
Finally, we must observe that the injury requirement is not satisfied by just any type of frustrated legal claim. Nearly all of the access-lo-courts cases in the Bounds line involved attempts by inmates to pursue direct appeals from the convictions for which they were incarcerated....
116 S.Ct. at 2181.
. As Justice Scalia points out in Lewis:
Justice SOUTER suggests that he would waive this actual-injury requirement in cases "involving substantial, systemic deprivation of access to court” — that is, in cases involving " ‘a direct, substantial and continuous ... limit on legal materials,’ ” "total denial of access to a library,” or " '[a]n absolute deprivation of access to all legal materials,' ” post, at 2204-05, and n. 2. That view rests upon the expansive understanding of Bounds that we have repudiated.
Lewis, 116 S.Ct. at 2181 n. 4.