The following excerpt is from Florence v. Frauenheim, CASE NO. 1:15-cv-01383-AWI-MJS (PC) (E.D. Cal. 2017):
Under the first element, plaintiff need not prove that the alleged retaliatory action, in itself, violated a constitutional right. Pratt v. Rowland, 65 F.3d 802, 806 (1995) (to
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