The following excerpt is from Belmonte v. Palomares, No. 2:19-cv-00163-TLN-CKD (E.D. Cal. 2020):
Rhodes, 408 F.3d at 568 (recognizing an arbitrary confiscation and destruction of property, initiation of a prison transfer, and assault as retaliation for filing inmate grievances); Pratt v. Rowland, 65 F.3d 802, 806 (9th Cir. 1995) (finding that a retaliatory prison transfer and double-cell status can constitute a cause of action for retaliation under the First Amendment).
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