Jan Gawlik v. Strom, et al.

Summary

The United States District Court for the District of Connecticut granted Defendants’ motion for summary judgment in Jan Gawlik’s First Amendment retaliation action. Gawlik alleged that Connecticut Department of Correction officials charged him for printouts and photocopies in retaliation for lawsuits he had filed. The court concluded that, although Gawlik exhausted his administrative remedies, he failed to show a causal connection between the copying charges and his protected litigation activity.

Holdings

1. Plaintiff exhausted his administrative remedies because his grievances identified the challenged charges and requested relief, and the PLRA and applicable prison directives did not require him to name every defendant or state the defendants' alleged retaliatory motive.
2. A First Amendment retaliation claim requires protected speech or conduct, adverse action, and a causal connection between the protected activity and the adverse action.
3. Defendants were entitled to summary judgment because Plaintiff presented no evidence from which a reasonable jury could find that the copy charges were causally related to his protected litigation activity.

Questions Presented

1. Whether Defendants waived or otherwise failed to preserve the PLRA exhaustion defense by not raising it in an earlier dispositive motion when the court expressly invited an early exhaustion motion.
2. Whether Plaintiff exhausted available administrative remedies despite not naming every Defendant and not using the word "retaliate" in his grievances.
3. Whether Plaintiff produced sufficient evidence to create a genuine dispute that charging him for printouts and photocopies was an adverse action causally connected to his protected filing of lawsuits.
4. Whether Defendants were entitled to summary judgment on Plaintiff's First Amendment retaliation claim.

Disposition

other