The following excerpt is from Garcia v. Foulk, No. 2:14-cv-2378 JAM DB P (E.D. Cal. 2020):
Further, an implication of defendants' argument is that the only conduct protected under the First Amendment is the filing of grievance forms. That argument is not well taken. Plaintiff alleges he was prevented from filing those grievances by the defendants. Further, case law establishes that filing a grievance or lawsuit is not the only activity protected under a First Amendment retaliation claim. See Pearson v. Welborn, 471 F.3d 732, 741 (7th Cir. 2006) (oral complaints about prison conditions are protected activity under the First Amendment).
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