may not retaliate against inmates for filing grievances. Regardless of whether Booker’s right was obvious or “manifestly apparent” from broader principles in the decisional law, we find that it was clearly established based on a robust “consensus of persuasive authority.” The Second, Sixth, Seventh, Eighth, Ninth, Eleventh, and D.C. Circuits have all recognized in published decisions that inmates possess a right, grounded in the First Amendment’s Petition Clause, to be free from retaliation in response to filing a prison grievance. T r. 2006) (“First Amendment rights to free speech and to petition the government for a redress of grievances are violated when a prisoner is punished for filing a grievance.... ”); Toolasprashad v. Bureau of Prisons, 286 F.3d 576, 584-85 (D.C. Cir. 2002) (<HOLDING>). Even more, the Third, Fifth, and Tenth
holding that an inmate has a first amendment right to file grievances against prison officials recognizing that prisoners undoubtedly exercise first amendment petition right when filing grievances and stating that prison officials may not retaliate against prisoners for filing grievances holding no first amendment right to file frivolous grievances holding that administrative remedies are unavailable if prison officials fail to respond to prisoners grievances recognizing first amendment petition right where inmate alleged retaliation for filing grievances