Charles Clagett, III v. J. Woodring, 686 F. App'x 426

Charles T. Clagett III, a federal inmate, sued prison officials under Bivens alleging First Amendment retaliation and Eighth Amendment deliberate indifference among other claims after being reassigned from education to food service.
Clagett’s transfer occurred shortly after an administrative grievance was denied and shortly after he filed the instant lawsuit.
Clagett alleges threats from Warden Woodring and evidence that education staff praised his performance and that higher-level staff ordered the transfer. Medical staff said they were pressured to clear him for food service.
Defendants contend the reassignment was motivated by suspicions that Clagett was doing improper legal work in the law library and point to declarations suggesting misconduct.
Clagett alleged physical harm from the food-service assignment; Dr. Evelyn Castro medically cleared him for food service but had no role in specific task assignments.
The district court granted summary judgment for most defendants; the Ninth Circuit affirmed in part and reversed in part after de novo review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reassignment was retaliatory in violation of the First Amendment	Clagett: transfer occurred after grievance/lawsuit and threats; evidence shows lack of legitimate penological motive	Defendants: reassignment based on suspicion Clagett improperly did legal work in library, a valid penological reason	Reversed: genuine dispute exists whether there was no legitimate penological goal; summary judgment for Woodring and Young improper
Whether Dr. Castro was deliberately indifferent under the Eighth Amendment by clearing Clagett for food service	Clagett: clearance caused assignment that required standing/bending aggravating his conditions	Dr. Castro: she only medically cleared him for food service after policy change; she had no control over specific assignments	Affirmed: no deliberate indifference because Castro lacked authority over specific work assignments
Scope of summary judgment review	Clagett: material factual disputes exist about motive and who initiated transfer	Defendants: witness declarations support nonretaliatory motive and justify summary judgment	Court: resolved de novo; viewed evidence in plaintiff’s favor where genuine disputes existed; reversed or affirmed accordingly
Claims not challenged on appeal	N/A	Defendants note some claims remain uncontested on appeal	Court did not address claims not challenged by Clagett’s brief (e.g., claims against Misra and others)

Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (establishing federal cause of action for constitutional violations by federal officers)
Rhodes v. Robinson, 408 F.3d 559 (9th Cir. 2005) (elements for prisoner First Amendment retaliation claim)
Pratt v. Rowland, 65 F.3d 802 (9th Cir. 1995) (recognizing legitimate penological interests can justify inmate restrictions)
Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference standard for inadequate medical care)
Shepard v. Quillen, 840 F.3d 686 (9th Cir. 2016) (noting triable facts may show actions motivated by retaliation rather than legitimate penological purpose)
Metropolitan Life Ins. Co. v. Parker, 436 F.3d 1109 (9th Cir. 2006) (standard of de novo review on appeal)