• U.S. District Court
  • Haight, J.
The 2012 Second Circuit in Sousa v. Marquez, while not officially recognizing "backward-looking" right of access to courts claims, suits that cannot now be tried, ruled that such claims "are not cognizable if the plaintiff, claiming that the government concealed or manipulated relevant facts, was aware at the time of the earlier lawsuit [or, presumably at the time of a potential earlier lawsuit] of the facts giving rise to his claim."