Brown v. Crowley.

• Position: Retaliation - Brief Article

U.S. Appeals Court

RETALIATION

Brown v. Crowley, 312 F.3d 782 (6th Cir. 2002). A state prison inmate brought a [section] 1983 action against prison officials, alleging that his prison account had been overcharged and that officials had retaliated against him for complaining about the overcharges. The district court dismissed or granted summary judgment for the officials on all claims. The appeals court vacated and remanded. The appeals court held the inmate stated a First Amendment retaliation claim when he alleged that he was charged with a major misconduct, even though he was already in administrative segregation. Although the prisoner was eventually found not guilty of...