grievance system or was otherwise disruptive or manipulative in any way that would entitle her to initiate punitive action against him. King was undeniably the litigious type. Aside from his participation in the Cain litigation, he was also involved in the filing of numerous grievances, both his own and assisting others. He was also a member of the Warden’s Forum. As a result, King undoubtedly had a certain level of respect and influence among the prisoners. This conduct — protected conduct — may undoubtedly create disruptions or “problems” for prison officials. But when that happens, the prison is not restricted from taking any action against the prisoner to minimize the disruption, it just must not take an adverse action against the prisoner. Ward v. Dyke, 58 F.3d 271, 274 (6th Cir.) (<HOLDING>), cert. denied, 516 U.S. 991, 116 S.Ct. 524,
holding no constitutional violation for taking action against prisoner whose numerous grievances were disruptive because chosen action did not deter him from exercising his rights holding that not all adverse action taken against a public employee in retaliation for exercising first amendment rights is sufficient to support a cause of action under  1983 recognizing cause of action against federal officials for violation of constitutional rights recognizing an action for damages against unknown federal agents for the violation of constitutional rights holding that because prisoner did not have private property interest in his prison accounts there could be no unconstitutional taking