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In our legal system, the meritorious claims of indigents are frequently not adjudicated, much less vindicated, because of governmentally-imposed costs of litigation. In some jurisdictions, relief from filing fees is available through the mechanism of proceeding in forma paiperis.1 Many states, however, make no such provision, and those that do frequently waive court fees only in certain actions. Moreover, there are other expenses, such as bond and notice costs, which confront many litigants and for which relief is generally unavailable.2 Relying on principles of due process and equal protection, the Supreme Court has already made tentative steps toward a right of judicial access for indigents. The scope of these decisions is limited, however, and the doctrines they invoke raise considerable difficulties. This Note suggests that a more comprehensive and workable theory of access may be developed on the basis of the First Amendment.3

A First Amendment Right of Access to the Courts for Indigents