The following excerpt is from Birdwell v. Martel, No. 2:10-cv-2523-TLN-EFB P (E.D. Cal. 2013):
Prisoners have a First Amendment right to be free from retaliation for participating in "protected speech activities." Pratt v. Rowland, 65 F.3d 802, 806 & n.4 (9th Cir.1995). Prisoners' constitutional right to access to the courts "extends to established prison grievance procedures." Bradley v. Hall, 64 F.3d 1276, 1279 (9th Cir. 1995), overruled on other grounds by
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