The following excerpt is from Knapp v. Hickman, No. CIV S-05-2520-FCD-CMK-P (E.D. Cal. 2011):
In order to state a claim for retaliation, a prisoner must establish the following: (1) prison officials took adverse action against the inmate; (2) the adverse action was taken because the inmate engaged in protected conduct; (3) the adverse action chilled the inmate's First Amendment rights; and (4) the adverse action did not serve a legitimate penological purpose. See Rhodes v. Robinson, 408 F.3d 559, 568-69 (9th Cir. 2005).
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