What is the cause of action against prison officials for failing to mail a complaint to the Department of Justice?

MultiRegion, United States of America

The following excerpt is from Gonzalez v. Gamberg, No. 2:14-cv-0737 KJM CKD P (E.D. Cal. 2015):

This action was not commenced by plaintiff until March 16, 2014, when he gave his complaint to prison officials for mailing. See Houston v. Lack, 487 U.S. 266, 270 (1988). Unless

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