Jeffery Walton v. Yolanda Gray, 695 F. App'x 144

Plaintiff Jeffery Walton, a Tennessee prisoner, sued WCF librarian Yolanda Gray and education principal Dana Bell under 42 U.S.C. § 1983 alleging denial of access to courts and retaliation after he missed a Tennessee Supreme Court appeal deadline.
Walton alleged Gray denied him library passes and access to legal aides in early February 2014; after he filed a grievance against Gray, her efforts to deny access increased and Walton missed his deadline.
Walton also alleged that on March 20, 2014 Bell requested his dismissal from a skilled prison job because Walton had filed grievances against Gray; he was later assigned to an unskilled job with half the pay.
The district court dismissed the amended complaint for failure to state a claim and denied leave to amend; Walton appealed the dismissal of his First Amendment retaliation claim.
The Sixth Circuit reviewed de novo and applied the Thaddeus‑X three‑element retaliation framework (protected conduct, adverse action, causal connection) and Iqbal/Twombly plausibility standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Walton engaged in protected conduct	Walton’s grievance against Gray over denial of legal access was protected First Amendment activity	District court: underlying denial-of-access claim failed, so the grievance was legally nonactionable/frivolous	Court: grievance was not frivolous; TDOC treated it as legitimate, so protected conduct was adequately alleged
Whether dismissal from skilled job is an adverse action	Loss of skilled job and pay cut would deter an ordinarily firm person from filing grievances	Defendants: no constitutional property right in prison employment so job loss cannot be adverse	Court: loss of a prison job can constitute an adverse action for retaliation purposes; district court erred in focusing on property‑right theory
Whether there is causal connection / retaliatory motive	Temporal proximity, Bell’s contemporaneous dismissal request referencing Walton’s grievances shows retaliatory motive	Defendants: actions were not motivated by retaliation (implicit)	Court: pleadings sufficiently allege causation; Bell’s statement and timing provide direct and circumstantial evidence of retaliatory motive

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim to relief)
Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (standard for §1915(e)(2)(B)(ii) and pleading plausibility)
Thaddeus‑X v. Blatter, 175 F.3d 378 (6th Cir. 1999) (en banc) (three‑element prisoner retaliation framework)
Herron v. Harrison, 203 F.3d 410 (6th Cir. 2000) (prisoner’s right to file grievances is protected if not frivolous)
Bell v. Johnson, 308 F.3d 594 (6th Cir. 2002) (definition of an adverse action in retaliation context)
Siggers‑El v. Barlow, 412 F.3d 693 (6th Cir. 2005) (loss of a prison job can be adverse action)
Shehee v. Luttrell, 199 F.3d 295 (6th Cir. 1999) (retaliation and adverse action principles)
Newsom v. Norris, 888 F.2d 371 (6th Cir. 1989) (no constitutional property right in prison employment)
Clemente v. Vaslo, 679 F.3d 482 (6th Cir. 2012) (failure to challenge claims on appeal constitutes abandonment)