The following excerpt is from Williams v. Santiago, CASE NO. 1:16-cv-01065-MJS (PC) (E.D. Cal. 2016):
With respect to the fifth prong, a detainee must affirmatively allege that the "authorities' retaliatory action did not advance legitimate goals of the [] institution or was not tailored narrowly enough to achieve such goals." Rizzo v. Dawson, 778 F.2d at 532.
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