The following excerpt is from Clifton v. Pierre, Case No. 1:13-cv-01325 DLB PC (E.D. Cal. 2015):
some adverse action against an inmate (2) because of (3) that prisoner's protected conduct, and that such action (4) chilled the inmate's exercise of his First Amendment rights, and (5) the action did not reasonably advance a legitimate correctional goal." Rhodes v. Robinson, 408 F.3d 559, 567-68 (9th Cir. 2005).
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