The following excerpt is from Davis v. Florence, No. 13-4604-pr (2nd Cir. 2015):
To make out a claim of retaliation under the First Amendment, an inmate must establish "(1) that the speech or conduct at issue was protected, (2) that the defendant took adverse action against the [inmate], and (3) that there was a causal connection between the protected [conduct] and the adverse action." Holland v. Goord, 758 F.3d 215, 225 (2d Cir. 2014) (second alteration in original) (quotation marks omitted).
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