district court erred in ruling that Bell had presented insufficient evidence to show that the defendants’ actions could deter a person of ordinary firmness from engaging in protected conduct. Initially, we note that a number of cases from other circuits have held that confiscating an inmate’s legal papers and other property constitutes sufficient injury to support a First Amendment retaliation claim. See Penrod v. Zavaras, 94 F.3d 1399, 1404 (10th Cir.1996) (reversing grant of summary judgment to defendants on inmate’s claim that guards conducted harassing cell searches, seized legal materials, refused to provide inmate with hygiene items, and transferred inmate to segregation in retaliation for suit against prison officials); Green v. Johnson, 977 F.2d 1383, 1389-91 (10th Cir.1992) (<HOLDING>); Wright v. Newsome, 795 F.2d 964, 968 (11th
holding that filing of a disciplinary charge becomes actionable if done in retaliation for the inmates filing of a grievance and stating that such conduct strikes at the heart of an inmates constitutional right to seek redress of grievances holding that inmates allegation that guards destroyed his legal materials in retaliation for his filing of suits and grievances stated a cognizable first amendment claim holding that a claim of retaliation for filing eeoc charges is cognizable under  1981 recognizing first amendment retaliation claim where official filed a disciplinary report following an inmates filing of a grievance recognizing first amendment petition right where inmate alleged retaliation for filing grievances