Germaine Smart v. COII Ronald England

U.S. Court of Appeals for the Eleventh Circuit
Germaine Smart v. COII Ronald England, 93 F.4th 1283 (11th Cir. 2024)

Germaine Smart v. COII Ronald England

Opinion

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                                                              [PUBLISH]
                                    In the
                 United States Court of Appeals
                         For the Eleventh Circuit

                           ____________________

                                 No. 22-11738
                           ____________________

        GERMAINE SMART,
                                                       Plaintiff-Appellant,
        versus
        COII RONALD ENGLAND,
        GARY MALONE,
        LARRY BAKER,


                                                   Defendants-Appellees.


                           ____________________

                  Appeal from the United States District Court
                     for the Northern District of Alabama
                   D.C. Docket No. 4:19-cv-00471-MHH-JHE
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        2                     Opinion of the Court                22-11738

                            ____________________

        Before WILLIAM PRYOR, Chief Judge, and ABUDU and ED CARNES,
        Circuit Judges.
        WILLIAM PRYOR, Chief Judge:
                This appeal requires us to decide whether prison officials
        Ronald England, Gary Malone, and Larry Baker enjoy qualified im-
        munity from prisoner Germaine Smart’s complaint of retaliation
        for exercising his right, under the First Amendment, to report offi-
        cial misconduct. Smart alleged that England sexually assaulted him
        during a pat-down search. After a prison investigator determined
        that Smart’s allegations of sexual assault were unfounded, England
        charged Smart with the disciplinary infraction of “Lying.” A disci-
        plinary tribunal later found that Smart’s allegations were false and
        sanctioned him for lying. The district court granted summary judg-
        ment for the officials based on qualified immunity. Because the of-
        ficials did not violate Smart’s First Amendment right, we affirm.
                                I. BACKGROUND
               In September 2016, Captain Gary Malone of the Alabama
        Department of Corrections ordered five prison officers, including
        Sergeant Ronald England, to search Germaine Smart’s cellblock.
        England approached Smart’s prison cell, ordered him to strip down
        to his boxer shorts, and instructed him to stick his arms out of the
        cell door tray hole so that Smart could be handcuffed for a “shake-
        down.” Smart exited his cell in only boxer shorts. Within view of
        two other prison officers and two prisoners in adjacent cells,
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        22-11738              Opinion of the Court                       3

        England conducted a pat-down search of Smart’s “waist band,
        groin and buttock area.” A pat-down search, under prison operat-
        ing procedures, requires “pressing one’s hands against and over the
        . . . clothed body” of the individual being searched. None of the
        witnesses observed—and Smart himself does not allege—that Eng-
        land removed Smart’s boxer shorts or touched Smart’s unclothed
        groin during the pat-down. England found no contraband and re-
        turned Smart to his cell without further incident.
               Smart filed an administrative complaint of misconduct a few
        days later. The complaint alleged that, during the pat-down, Eng-
        land “began to fondle Smart[’]s penis and scrotum,” at which point
        Smart interjected, “What the f--k are you doing grabbing my d--k
        and nuts . . . I’m not gay!” England allegedly “snickered with a
        smile showing gratifying sexual desire.”
               The prison conducted an administrative investigation in re-
        sponse to Smart’s complaint. The Investigations and Intelligence
        Division assigned George Bynum to investigate. Bynum inter-
        viewed seven witnesses: Smart, England, two other prisoners, and
        three other prison officers. During his interview, Smart reiterated
        his written account that England had “fondle[d]” his penis. Both
        prisoners corroborated Smart’s complaint. Smart’s cellblock neigh-
        bor recounted that during the search, Sergeant England had
        “pulled on inmate Smart’s private part twice.” And the prisoner
        who occupied the cell across from Smart recounted that Sergeant
        England had “massaged inmate Smart[’s] penis.” The prison offic-
        ers, in contrast, denied seeing any misconduct. The two closest
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        4                     Opinion of the Court                22-11738

        officers, who were about three and eight feet away respectively,
        reported that England had “conducted a pat-search[]”and had
        “checked [Smart’s] waist band and groin area.”
               In his investigative report, Bynum found that England
        “properly patted down inmate Smart” and “follow[ed the prison’s]
        Standard Operating Procedure” for “performing a pat-down
        search.” The standardized report form provides only four options
        for case dispositions: “Substantiated,” “Unsubstantiated,” “Un-
        founded,” and “Cleared by Arrest.” Bynum marked the case dispo-
        sition “Unfounded,” which is the option that most strongly corre-
        sponds to falsity—it means the allegation “was investigated and de-
        termined not to have occurred.” Ala. Dep’t of Corr. Admin.
        Reg. 454, § III(A)(2). Bynum’s supervisors approved his report a
        week later.
               England initiated disciplinary proceedings against Smart.
        Two days after the approval of Bynum’s report, England served
        Smart with a preliminary disciplinary report charging him with
        “Lying,” a medium-level disciplinary infraction. The Department
        regulations define “Lying” as “[g]iving false testimony or making a
        false charge to an employee with the intent to deceive the em-
        ployee or to prejudice another person.” Ala. Dep’t of Corr. Admin.
        Reg. 403, Rule 512. The regulations also prohibit “issu[ing]” a dis-
        ciplinary report for lying based “solely” on an “unfounded” sexual
        assault accusation:
              Disciplinary action may be taken when an investiga-
              tion by the IPCM and/or I&I Investigator determines
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        22-11738               Opinion of the Court                         5

              that an inmate made a false report of sexual abuse or
              sexual harassment.

              However, an inmate reporting sexual abuse or sexual
              harassment, shall not be issued a disciplinary report
              for lying based solely on the fact that their allegations
              were unfounded or that the inmate later decides to
              withdraw his / her allegation.

        Ala. Dep’t of Corr. Admin. Reg. 454, § V(H)(2)(b), (c). After being
        served with the report, Smart refused to sign it and denied guilt.
               To adjudicate whether Smart had committed the infraction
        of “Lying,” the prison held a disciplinary hearing. Lieutenant Larry
        Baker oversaw that hearing. Smart was given the opportunity to
        submit pre-hearing questions to three individuals that Bynum had
        interviewed: two prisoners and a prison officer. Smart also called
        those individuals to testify at the hearing. One prisoner testified
        that he “saw [Sergeant] England grab inmate Smart[’s] penis,” and
        the other testified that “England reach[ed] around and grabbed in-
        mate Smart[’s] penis.” The prison officer testified that, during the
        pat-down, he “heard inmate Smart make the allegation that [Ser-
        geant] England grabbed his penis.” England testified that he denied
        the allegation.
               At the close of the disciplinary hearing, Baker found Smart
        guilty of “Lying.” As the basis for his finding, Baker stated that he
        “believe[d] the sworn testimony” of England that he “conducted a
        pat search” of Smart, and “accept[ed] the finding of I & I investiga-
        tor Bynum” that Smart’s allegations were unfounded. Baker
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        6                      Opinion of the Court                 22-11738

        recommended the loss of privileges for 30 days and disciplinary seg-
        regation for 21 days, and Malone approved the sanctions.
                Smart filed suit pro se. He alleged that prison officials Eng-
        land, Baker, and Malone “retaliated against [him] for reporting the
        incident of sexual assault” in violation of the First Amendment. See
        
42 U.S.C. § 1983
. Smart demanded injunctive relief and $100,000 in
        damages. In lieu of discovery, a magistrate judge ordered the offi-
        cials to file a special report with the sworn testimony of all knowl-
        edgeable individuals, which would be treated as a motion for sum-
        mary judgment. All three officials invoked qualified immunity.
               Smart opposed the motion and argued that England’s “un-
        lawful issuance” of the disciplinary report was “motivated by his
        desire to discredit Plaintiff[’s] ‘protected speech’” and to “white-
        wash Defendant England[’s] abussive [sic], and shameful homosex-
        ual act.” Smart asserted that the prison regulations gave England
        and Baker “no leeway or authority” to issue the disciplinary report.
               The magistrate judge recommended granting the officials’
        motion for summary judgment. He found that qualified immunity
        barred Smart’s complaint because no clearly established law pro-
        hibited the officials from disciplining Smart. The district court
        adopted the magistrate judge’s recommendation and granted sum-
        mary judgment for the officials. It found that no clearly established
        law put the officials on notice that violating Department Regula-
        tion 454 could be unconstitutional retaliatory conduct.
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        22-11738               Opinion of the Court                          7

                           II. STANDARD OF REVIEW
               We review de novo a summary judgment based on qualified
        immunity. Williams v. Aguirre, 
965 F.3d 1147
, 1156 (11th Cir. 2020).
        Summary judgment is appropriate when “there is no genuine dis-
        pute as to any material fact and the movant is entitled to judgment
        as a matter of law.” FED. R. CIV. P. 56(a).
                                 III. DISCUSSION
                State officials enjoy qualified immunity from complaints for
        damages under section 1983 when they act within their discretion-
        ary authority and do not violate any clearly established federal
        right. See Laskar v. Hurd, 
972 F.3d 1278, 1284
 (11th Cir. 2020). An
        official “bears the initial burden to prove that he acted within his
        discretionary authority.” Dukes v. Deaton, 
852 F.3d 1035, 1041
 (11th
        Cir. 2017). Officials who satisfy that burden are entitled to qualified
        immunity unless “(1) they violated a federal statutory or constitu-
        tional right, and (2) the unlawfulness of their conduct was clearly
        established at the time.” Laskar, 
972 F.3d at 1284
 (quoting District
        of Columbia v. Wesby, 
138 S. Ct. 577, 589
 (2018)) (internal quotation
        marks omitted).
                Smart makes two arguments for reversal. He argues that the
        officials lacked the discretionary authority to violate prison admin-
        istrative regulations. He also argues that the officials violated his
        clearly established right, under the First Amendment, to be free
        from retaliation after filing a complaint of sexual assault. We reject
        both of Smart’s arguments in turn.
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        8                      Opinion of the Court                 22-11738

             A. The Officials Acted Within Their Discretionary Authority.
                To be eligible for qualified immunity, an official must prove
        that he was performing a “discretionary function” when he en-
        gaged in the alleged conduct. Holloman ex rel. Holloman v. Harland,
        
370 F.3d 1252, 1264
 (11th Cir. 2004) (quoting Harlow v. Fitzgerald,
        
457 U.S. 800, 818
 (1982)) (internal quotation marks omitted). The
        official acts within his discretionary authority when he “perform[s]
        a legitimate job-related function . . . through means that were
        within his power to utilize.” Id. at 1265. We examine a job-related
        function at “a general level rather than in [a] specific application,”
        while taking care not to assess the function at “such a high level of
        abstraction” that “it becomes impossible to determine whether the
        employee was truly acting within the proper scope of his job-re-
        lated activities.” Id. at 1266–67.
               The officials exercised discretionary authority. We have re-
        peatedly explained that the “administration of discipline” is a job-
        function defined at the appropriate level of generality for the anal-
        ysis of a public official’s discretionary authority. Id. (citation and
        internal quotation marks removed) (explaining that disciplining a
        student was a “legitimate prerogative[]” of a teacher’s job); see also
        Harbert Int’l Inc. v. James, 
157 F.3d 1271
, 1282–83 (11th Cir. 1998)
        (concluding that public officials’ “discretionary duties included the
        administration of discipline”); Sims v. Metro. Dade County, 
972 F.2d 1230
, 1236 (11th Cir. 1992) (same). Prison officials’ duties include
        disciplining prisoners for behavioral infractions. See 
Ala. Code § 14
-
        1-4(a) (providing that the Department shall determine the
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        22-11738                Opinion of the Court                          9

        “qualifications, duties, and authority” of prison officials); Ala. Dep’t
        of Corr. Admin. Reg. 403 (defining the infractions, including “Ly-
        ing,” for which officials may administer discipline). So the officials
        performed a legitimate, job-related function when they disciplined
        Smart for violating a prison rule prohibiting lying.
               Our dissenting colleague asserts that the officials exceeded
        their discretionary authority by violating Regulation 454 and by
        conducting an “unlawful hearing” to adjudicate whether Smart
        lied. Dissent at 15. But our colleague misreads Regulation 454. See
        Ala. Dep’t of Corr. Admin. Reg. 454. That regulation does not al-
        together prohibit prison officials from disciplining a prisoner after
        a false sexual assault allegation. Indeed, section V(H)(2)(b) of the
        regulation expressly allows such disciplinary actions. 
Id.
        § V(H)(2)(b) (“Disciplinary action may be taken when an investiga-
        tion by the . . . [Investigations and Intelligence] Investigator deter-
        mines that an inmate made a false report of sexual abuse or sexual
        harassment.”).
               Regulation 454 instead provides heightened procedural pro-
        tections for prisoners who have made sexual assault allegations:
        section V(H)(2)(c) provides that a prisoner cannot be “issued a dis-
        ciplinary report for lying” based “solely on the fact that their allega-
        tions were unfounded.” Id. § V(H)(2)(c) (emphasis added). The
        phrase “issued a disciplinary report” is best read to mean the final
        imposition of sanctions, not the serving of charges on a prisoner. The
        overall report—i.e., the portions incorporating the officer’s factual
        findings, determination of guilt, and recommended sanctions—is
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        10                     Opinion of the Court                 22-11738

        labeled the “Disciplinary Report.” The charging form comprises
        only the first page of the disciplinary report. And the report refers
        to the delivery of notice of a disciplinary charge to a prisoner as
        “serv[ing],” not “issu[ing],” the report. In other words, section
        V(H)(2)(c) requires final sanctions to be based on more than “solely”
        on an investigative finding. Prison officers owe a prisoner process
        and the consideration of more evidence than a singular investiga-
        tor’s report, before sanctioning him for lying about sexual assault.
                Regulation 454 does not forbid officers from initiating the
        disciplinary process, “serv[ing]” a prisoner with charges, or holding
        a disciplinary hearing. To read the regulation otherwise would
        eliminate section V(H)(2)(b)’s express provision for disciplinary ac-
        tions against prisoners who make false allegations. Id. § V(H)(2)(c).
        Regulation 454 could not forbid officers from conducting a hearing
        after an investigative determination of “unfounded,” because every
        such disciplinary action would follow an “unfounded” determina-
        tion—the investigative report form provides “unfounded” as the
        option most evidencing falsity, and there is no option for “false.”
        So the officials did not violate Regulation 454 by charging Smart.
               Nor did the officers issue Smart a disciplinary report based
        “solely” on Bynum’s investigative finding that Smart’s allegations
        were “unfounded.” Instead, the officers held a full disciplinary hear-
        ing to adjudicate whether Smart had lied: Smart and England testi-
        fied before a hearing officer who had the opportunity to assess their
        credibility; Smart submitted written questions to three additional
        witnesses; and those witnesses testified by at the hearing and had
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        22-11738               Opinion of the Court                         11

        their statements incorporated into the disciplinary report. As the
        basis for the guilty determination and sanctions, the hearing officer
        credited not only Bynum’s report, but also “the sworn testimony
        of [Sergeant] England.” So the officers complied with Regulation
        454 and acted within the scope of their discretionary authority in
        disciplining Smart.
           B. The Officials Did Not Violate Smart’s First Amendment Right.
                Smart contends that the officials retaliated against him in vi-
        olation of his right to the freedom of speech. For Smart to establish
        a violation of his constitutional right, he had to prove that he en-
        gaged in protected speech, that officials retaliated against him, an
        adverse effect on his protected speech, and a causal relationship be-
        tween the retaliation and the adverse effect. See Bennett v. Hendrix,
        
423 F.3d 1247, 1250
 (11th Cir. 2005). A prisoner may state a claim
        under the First Amendment when he alleges that he was “punished
        for filing a grievance concerning the conditions of his imprison-
        ment.” Boxer X v. Harris, 
437 F.3d 1107, 1112
 (11th Cir. 2006), abro-
        gated in part on other grounds by Wilkins v. Gaddy, 
559 U.S. 34
 (2010).
        But we have held that a prisoner’s violation of a prison regulation
        is unprotected by the First Amendment. See O’Bryant v. Finch, 
637 F.3d 1207, 1215
 (11th Cir. 2011); Smith v. Mosley, 
532 F.3d 1270, 1277
        (11th Cir. 2008) (“[I]f a prisoner violates a legitimate prison regula-
        tion, he is not engaged in protected conduct [under the First
        Amendment].” (citation and internal quotation marks omitted)).
              A prisoner cannot prove a claim of retaliation based on a
        prison disciplinary charge when “the inmate was found guilty of
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        12                     Opinion of the Court                 22-11738

        the actual behavior underlying that charge.” O’Bryant, 
637 F.3d at 1215
. A prison tribunal’s finding that a prisoner committed the dis-
        ciplinary infraction is dispositive, so long as the prisoner was af-
        forded due process and “some evidence in the record” supports the
        finding of guilt. 
Id. at 1213
 (emphasis omitted) (quoting Superinten-
        dent v. Hill, 
472 U.S. 445, 454
 (1985)). Due process in this context
        “does not require examination of the entire record, independent
        assessment of the credibility of witnesses, or weighing of the evi-
        dence.” 
Id.
 (citation and internal quotation marks omitted). And
        the “some evidence” standard is satisfied by even a “meager” show-
        ing, so long as “the record is not so devoid of evidence” as to render
        the tribunal’s determination “arbitrary.” Hill, 
472 U.S. at 457
.
               Smart argues that our holding in O’Bryant and Mosley—that
        an actual disciplinary violation is unprotected under the First
        Amendment—does not apply when the officials unlawfully initi-
        ated the disciplinary proceedings. According to Smart, England vi-
        olated Regulation 454 by unlawfully charging Smart with “Lying”
        after Smart’s sexual assault complaint was determined to be un-
        founded. See Ala. Dep’t of Corr. Admin. Reg. 454, § V(H)(2)(c). But
        as we have explained, Smart misreads Regulation 454. The officials
        complied with prison regulations in issuing Smart’s disciplinary re-
        port, so there is no reason to depart from our precedents.
              O’Bryant and Mosley control. The officials afforded Smart
        due process—a tribunal before which he testified and presented ev-
        idence—and found him guilty based on “some evidence.” See Hill,
        
472 U.S. at 457
. So whether Smart “actually committed the charged
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        22-11738               Opinion of the Court                        13

        infraction” of lying, and whether “the disciplinary report falsely ac-
        cuses [Smart] are questions of fact that are decided by the discipli-
        nary panel.” O’Bryant, 
637 F.3d at 1215
. To conclude otherwise
        would “render the prison disciplinary system impotent by inviting
        prisoners to petition the courts for a full retrial each time they are
        found guilty of an actual disciplinary infraction after having filed a
        grievance.” 
Id. at 1216
. And like in Mosley, Smart’s administrative
        complaint “included false statements and w[as], thus, unprotected
        speech.” Dissent at 21 (citing Mosley, 
532 F.3d at 1276
). Because a
        prison tribunal found that Smart committed the actual disciplinary
        infraction of “Lying” after a hearing, he cannot “state a retaliation
        claim against the prison employee who reported [his] infraction.”
        O’Bryant, 
637 F.3d at 1215
. The officials enjoy qualified immunity.
               We agree with our dissenting colleague that reports of “ram-
        pant sexual abuse” and the high incidence of sexual assault allega-
        tions against prison officers are deeply troubling. Dissent at 7–13.
        But we cannot endorse an approach that allows population-level
        crime statistics to affect the determination of an individual defend-
        ant’s culpability. A “pattern” of misconduct within a population, id.
        at 13, does not make a particular defendant culpable. That prison
        officers are reported to commit “physical and sexual violence” at
        elevated rates, see id. at 12, has no bearing on whether England as-
        saulted Smart. Nor can statistical evidence diminish the procedural
        protections to which England is entitled. Where Smart’s allegations
        against England were found to be untruthful by both a prison in-
        vestigator and a disciplinary tribunal, Smart does not get a third
        bite of the apple in the form of this suit for $100,000 in damages.
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        14                  Opinion of the Court             22-11738

                            IV. CONCLUSION
              We AFFIRM the judgment for England, Malone, and Baker.
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        22-11738               ABUDU, J., Dissenting                      1

        ABUDU, Circuit Judge, Dissenting:
               This case presents the issue of whether Germaine Smart,
        who is incarcerated at the St. Clair Correctional Facility in Ala-
        bama, can be charged and punished with “lying” for accusing a
        prison guard of sexual assault—even though the investigation upon
        which the charge and punishment were based only determined that
        Smart’s allegations against the guard were “unfounded” as opposed
        to untruthful. Because the First Amendment, the Prison Rape
        Elimination Act (“PREA”), and the PREA-based regulations that
        the Alabama Department of Corrections promulgated clearly es-
        tablish that prison officials cannot punish an inmate for filing an
        “unfounded” grievance, the district court erred in granting Defend-
        ants Sergeant Ronald England, Captain Gary Malone, and Lieuten-
        ant Larry Baker qualified immunity. Therefore, the district court’s
        grant of summary judgment should be reversed, and the case
        should be remanded for further proceedings.
           I. SMART’S ALLEGATIONS OF SEXUAL ASSAULT AND
              DEFENDANTS’ RESPONSE
                On or around September 6, 2016, Malone ordered England
        and other guards to search Smart’s cell block based on a tip that
        another inmate might be planning to escape. At approximately
        9:00 p.m., England approached Smart’s cell to conduct a search.
        Given the late hour, Smart was lying on his bunk, but he was still
        fully clothed. England ordered Smart to take off all his clothes ex-
        cept for his underwear and to put his arms out of the tray hole so
        that England could handcuff him. Smart—in his underwear,
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        2                         ABUDU, J., Dissenting                    22-11738

        handcuffed, and outside of his cell in view of other inmates and
        guards—turned around at England’s direction so that England
        could physically search him. According to Smart, during the
        search, England began fondling his penis and scrotum. England
        never denied that Smart was partially naked and that he touched
        Smart’s genitals. Smart, who was shocked and offended by Eng-
        land’s manner of touching him, yelled out: “What the fuck are you
        doing grabbing my dick and nuts [?] I’m not gay!” Instead of ex-
        plaining to Smart why the physical search of his penis and scrotum
        was proper, or expressly denying that he did anything inappropri-
        ate, England just snickered and ordered Smart to step aside so he
        could search his cell. England left after not finding any contraband
        in Smart’s cell. While it is undisputed that England touched
        Smart’s genitals and scrotum, a question of fact remains as to
        whether England’s conduct rose to the level of sexual abuse or was
        in accordance with St. Clair’s strip search policy. Regardless, at this
        stage of the litigation, we must accept Smart’s allegation that Eng-
        land inappropriately touched him in violation of prison policies.
               On either September 8 or 9 1, Smart filed a formal grievance
        against England for sexual abuse and reported the inappropriate
        conduct to Malone. In his grievance, Smart identified three wit-
        nesses to the abuse who corroborated Smart’s account—two indi-
        viduals who were incarcerated in cells near him and a prison guard


        1 Although Smart’s pro se Complaint states September 8, 2016, as the date he
        reported the incident, the investigative report states that Smart reported the
        incident on September 9, 2016.
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        22-11738               ABUDU, J., Dissenting                      3

        who was present during the incident. Malone reported the incident
        to the Alabama Department of Corrections (“ADOC”) Investiga-
        tions and Intelligence Division (“I&I”), which is responsible for,
        among other things, “[e]nsuring that all allegations of sexual abuse
        and harassment are thoroughly investigated,” “[r]eferring viola-
        tions of law to the district attorney for prosecution,” “[r]eporting
        statistical data for PREA[-]related incidents,” and informing the
        person who reported the assault of the outcome of the investiga-
        tion. See Ala. Dep’t of Corr. Admin. Reg. 454, § IV(C).
               The ADOC assigned I&I Investigator George Bynum to the
        matter. The record shows that Bynum interviewed Smart, Eng-
        land, and the three other witnesses Smart identified. When inter-
        viewed, Smart reiterated the same facts asserted in his grievance,
        and England maintained that the pat down was just him “doing his
        job and not for sexual gratification.” One of the witnesses, Franky
        Johnson, stated that he was standing at his cell door window during
        the September 6 search and observed England pull on Smart’s “pri-
        vate part[s]” twice. The second witness, Timothy Gayle, was
        housed in a cell across from Smart’s and said that he saw England
        reach around Smart and massage Smart’s penis. He also heard
        Smart yell out in objection.
               About two months later, Bynum interviewed Lieutenant
        Russell Jones who was present as well during the search. Jones de-
        scribed Smart as “belligerent” and “loud,” but eventually compli-
        ant. He acknowledged that England physically touched “Smart’s
        waistband, groin, and buttock area.” Six months after the incident,
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        4                      ABUDU, J., Dissenting              22-11738

        Bynum interviewed Smart’s third identified witness, Officer Cam-
        eron Smith—who was “three to four” feet away from Smart and
        England, and observed Smart exit the cell only in his boxers. Smith
        stated England conducted a search of Smart’s “person and cell.”
               On March 6, 2017, Bynum completed his investigative re-
        port and found that Smart’s grievance against England for sexual
        assault was “[u]nfounded.” He summarily concluded that England
        “properly patted down inmate Smart over the outside of his boxer
        shorts, following Standard Operating Procedure # 110 for perform-
        ing a Shakedown/Pat Search or Frisk.” Although the form pro-
        vided a space for further written comments, Bynum did not pro-
        vide any. For example, Bynum did not write an assessment of why
        Smart, Johnson, and Gayle lacked credibility; he did not explain
        why he believed England’s version of events; and he did not in-
        clude any notes remotely suggesting that Smart fabricated a story.
        Nor did he note that Johnson and Gayle somehow conspired with
        Smart to make a false claim against England—a risky action to take
        given the associated punitive consequences of doing so.
               Two days after Bynum finalized his report, England charged
        Smart with “lying” about the sexual abuse allegation by issuing him
        a document titled “Disciplinary Report.” Under a section titled,
        “Circumstances of Violation,” England wrote: “You inmate Ger-
        maine Smart B/M 193127 made an allegation against Sergeant
        Ronald England on 09/09/2016. Further [i]nvestigation by I & I
        Investigator George Bynum completed . . . on 03/06/2017.
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        22-11738               ABUDU, J., Dissenting                      5

        Disposition [s]howed this case ‘Unfounded and Closed.’ There-
        fore, you are being charged for Lying.”
               Smart denied England’s assertion that he lied about the inci-
        dent. Baker conducted a hearing on the charge during which Smart
        again maintained that everything in his grievance was true. In ad-
        dition to Gayle and Johnson, who submitted both oral and written
        testimony reiterating that they had seen England “grab” Smart’s
        penis, Smart called Officer Smith as a witness. Officer Smith testi-
        fied that he heard Smart burst something out about “England grab-
        bing and fondling with [Smart’s] penis.” England, who requested
        St. Clair punish Smart by charging him with lying, did not deny
        Smart’s allegation at all. In fact, England’s testimony only con-
        sisted of three undisputed facts: “On September 9, 2016, I Sergeant
        Ronald England conducted a pat search of inmate Germaine Smart
        b/193127 C-5 cell. After the search, inmate Smart alleged that I
        Sgt. England grabbed his genitals inappropriately. I&I conducted
        an investigation into the incident and found that the allegations
        were unfounded.” England did not present any other evidence,
        and he failed to challenge the credibility of Smart’s two witnesses
        who both saw England sexually abusing Smart.
               At the conclusion of the hearing, Baker made a single factual
        finding: “Smart[’s] allegation against Sgt. England is unfounded.”
        As opposed to the seven months it took the prison to investigate
        and resolve Smart’s grievance regarding sexual abuse, England’s
        disciplinary action against Smart was received, reviewed, investi-
        gated, and resolved within five days of Bynum’s report. There is
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        6                          ABUDU, J., Dissenting                     22-11738

        no indication in the record that Baker ever read Bynum’s report,
        yet Baker credited it and “believe[d]” England’s testimony.
        Malone—who had ordered the search in the first place—adopted
        Baker’s determination that Smart had lied. He placed Smart in dis-
        ciplinary isolation for twenty-one days, stripped him of access to
        the canteen and telephone for thirty days, and denied him visitation
        privileges for thirty days.
                Proceeding pro se, Smart filed a sworn, verified complaint
        on March 21, 2019, alleging that England sexually assaulted him in
        violation of his Eighth Amendment rights, and that prison officials
        unlawfully retaliated against him for filing a grievance in violation
        of his First Amendment rights. 2 Smart subsequently requested, and
        the court granted, leave to add two additional defendants to his
        complaint, Malone and Baker. England, Malone, and Baker filed
        Special Reports that included their sworn statements, which were
        construed as Defendants’ motion for summary judgment. Ulti-
        mately, the district court granted Defendants summary judgment,
        finding that they were entitled to qualified immunity.




        2 The magistrate judge ruled that Smart’s Eighth Amendment claim was time-
        barred. Smart did not contest that ruling below and does not raise it on appeal.
        Therefore, the only issue before us is whether Defendants violated Smart’s
        First Amendment rights by retaliating against him for filing a grievance accus-
        ing England of sexual assault.
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        22-11738                ABUDU, J., Dissenting                        7

           II. PREA AND ALABAMA’S REGULATIONS
               Smart’s claim for sexual assault and retaliation echoes that
        of countless others in the American criminal legal system. Sexual
        abuse in prison has long terrorized those under correctional con-
        trol. Indeed, it has been called “America’s most ‘open’ secret.” See
        Chandra Bozelko, Why We Let Prison Rape Go On, N.Y.TIMES (April
        17, 2015), https://perma.cc/DX2S-S7NJ (“According to the Bureau
        of Justice Statistics, around 80,000 women and men a year are sex-
        ually abused in American correctional facilities. That number is
        almost certainly subject to underreporting, through shame or a vic-
        tim’s fear of retaliation.”).
                To tackle the issue of rampant sexual abuse in jails and pris-
        ons, Congress enacted PREA in 2003. See 34 U.S.C. §§ 30301–
        30309. Congress found that “[m]embers of the public and govern-
        ment officials [were] largely unaware of the epidemic character of
        prison rape and the day-to-day horror experienced by victimized
        inmates.” 
34 U.S.C. § 30301
(12). It also found that, by conservative
        estimates, “at least 13 percent of the inmates in the United States
        ha[d] been sexually assaulted in prison,” 
id.
 § 30301(2), and that
        “[p]rison rape often [went] unreported” with “inmate victims often
        receiv[ing] inadequate treatment for the severe physical and psy-
        chological effects of sexual assault—if they receive[d] treatment at
        all,” id. § 30301(6). At the time it enacted PREA, Congress found
        that “[t]he total number of inmates who [had] been sexually as-
        saulted in the past 20 years likely exceeds 1,000,000.” Id. § 30301(2).
        PREA’s purpose was to establish a “zero-tolerance standard for the
        incidence of prison rape” in the United States, id.§ 30302(1), and “to
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        8                       ABUDU, J., Dissenting                 22-11738

        develop and implement national standards for the detection, pre-
        vention, reduction, and punishment of prison rape,” id. § 30302(3).
        Rape, as defined by PREA and relevant here, includes “the sexual
        fondling of a person forcibly or against that person’s will.” Id. §
        30309(9)(A).
               To help accomplish the statute’s goals, PREA mandated the
        issuance of national standards, including guidance on how to ad-
        dress sexual acts by prison staff members against people under their
        correctional control. See id. § 30306 (a),(d); 
28 C.F.R. §§ 115.5
-
        115.501. Unfortunately, it took the United States Department of
        Justice (“DOJ”) almost ten years to issue those national standards.
        See 
28 C.F.R. §§ 115.5-115.501
. The standards expound on the def-
        initions of rape in PREA and specifically define terms like “sexual
        abuse” and “sexual harassment.” For example, “sexual abuse,” in-
        cludes “[a]ny [] intentional contact, either directly or through the
        clothing, of or with the genitalia, anus, groin, breast, inner thigh,
        or the buttocks, that is unrelated to official duties . . . .” 28 C.F.R.
        115.6(5). The standards also identify ways prisons can respond to
        and investigate allegations of sexual abuse by guards or other in-
        mates against incarcerated individuals, and they also outline proce-
        dures prisons must follow to protect individuals from retaliation
        when reporting abuse. See generally 
id.
 §§ 115.5-115.501; 
28 C.F.R. §§ 115.51
(a), 115.67. Despite these guidelines, incidents of sexual
        abuse in our nation’s jails and prisons are likely much higher than
        what is reported given that less than half of the victims of sexual
        abuse report the abuse themselves. See, e.g., U.S. DEP’T. OF JUST.,
        BUREAU OF JUST. STAT., Substantiated Incidents of Sexual Victimization
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        22-11738                 ABUDU, J., Dissenting                         9

        Reported by Adult Correctional Authorities, 2016-2018 10 (Jan. 2023),
        https://perma.cc/2MEV-JZW6 (noting that more than half of the
        incidents of staff-on-inmate sexual violence nationwide were re-
        ported by someone other than the victim). The underreporting is
        likely even more prevalent among men. See Colette Marcellin and
        Evelyn F. McCoy, URB. INST., Preventing and Addressing Sexual Vio-
        lence in Correctional Facilities: Research on the Prison Rape Elimination
        Act 10 (2021), https://perma.cc/9QYZ-L953.
                Every single detention facility in the United States is re-
        quired to comply with these standards; otherwise, they risk losing
        certain federal funding. See 
34 U.S.C. § 30306
(e)(2). ADOC’s Ad-
        ministrative Regulation 454 (“AR 454”) represents ADOC’s effort
        to implement, and therefore, advance PREA’s goal of ensuring that
        institutional facilities are free from sexual violence. Its definition
        of “sexual abuse,” like that of the national regulations, covers con-
        duct by a correctional officer and includes “intentional contact, ei-
        ther directly or through the clothing, of or with the genitalia . . .
        that is unrelated to official duties or where the staff member . . . has
        the intent to abuse, arouse, or gratify sexual desire.” Ala. Dep’t of
        Corr. Admin. Reg. 454, § III(L).
               To ensure those who report sexual abuse are not retaliated
        against, AR 454 § V(H)(2)(c) specifically forbids officials from
        “issu[ing] a disciplinary report for lying based solely on the fact
        that” an inmate’s sexual abuse “allegations were unfounded.” Ala.
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        10                         ABUDU, J., Dissenting                      22-11738

        Dep’t of Corr. Admin. Reg. 454, § V(H)(2)(c). 3 Individuals in cus-
        tody, however, are not given carte blanche to make baseless sexual
        abuse accusations fueled by some ulterior motive. Section
        V(H)(2)(b), therefore, allows a correctional facility to take “discipli-
        nary action” when an “I&I Investigator determines that an inmate
        made a false report of sexual abuse or harassment.” Id.
        § V(H)(2)(b).
               AR 454 has not had its intended effect. Sexual abuse in pris-
        ons and jails remains a persistent problem in Alabama. For exam-
        ple, in 2014, the DOJ investigated the Julia Tutwiler Prison for
        Women and found the prison had a “history of unabated staff-on-
        prisoner sexual abuse and harassment” which was “grossly


        3 Notably, § V(H)(2)(c) uses the word “issue” before disciplinary report as op-
        posed to “impose” or “serve.” “[A] regulation should be construed to give
        effect to the natural and plain meaning of its words.” Ala. Air Pollution Control
        Comm’n v. Republic Steel Corp., 
646 F.2d 210, 213
 (5th Cir. 1981). The word
        “issue” means “to send out, put into circulation, distribute or publish.” Gris-
        wold v. United States, 
59 F.3d 1571, 1580
 (11th Cir. 1995) (citing The Random
        House Dictionary of the English Language 1015 (2d ed. 1987)). The word “im-
        pose”—in the context of a punishment—means “to make, frame, or apply . . .
        as compulsory, obligatory or enforceable.” Impose, Merriam-Webster’s Una-
        bridged Dictionary, https://perma.cc/7P4A-BPAX (last visited February 7, 2024).
        While a document such as a disciplinary report may be issued, stating one may
        be “imposed” does not make much sense. Section V(H)(2)(c) therefore clearly
        and accurately states that a disciplinary report shall not be “issued.” It also
        makes no distinction between a “preliminary” disciplinary report or a “final”
        one. If “issuing a disciplinary report” was supposed to mean “issuing a prelim-
        inary disciplinary report,” the text would say so. It does not.
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        22-11738                ABUDU, J., Dissenting                        11

        underreported,” in part, due to “a heightened fear of retaliation[]
        and an inadequate investigative process.” Letter from Jocelyn Sam-
        uels, Acting Assistant Att’y Gen., U.S. Dep’t of Just., to Robert
        Bentley, Governor, State of Ala. (Jan. 17, 2014),
        https://perma.cc/VE3D-Z9LB (noting prison staff have “raped,
        sodomized, fondled, and exposed themselves to prisoners. They
        have coerced prisoners to engage in oral sex. Staff engage[d] in vo-
        yeurism, forcing women to disrobe and watch[ed] them while they
        use the shower and use the toilet.”). Similarly, in 2020, an Alabama
        deputy sheriff arrested a woman for a traffic stop and forced her to
        perform oral sex on him against her will while she was in his cus-
        tody. Press Release, U.S. DEP’T OF JUST., Former Alabama Deputy
        Sheriff Sentenced for Sexually Assaulting a Woman in His Custody (Aug.
        25, 2023), https://perma.cc/65NR-KG88. The deputy was prose-
        cuted in federal court for the sexual assault and sentenced to twelve
        and a half years in prison. 
Id.
                Continued reports of sexual abuse and violence in Alabama
        required the DOJ to step in and investigate whether the ADOC was
        protecting its prisoners from physical and sexual violence within its
        facilities, including St. Clair. U.S. DEP’T OF JUST. CIV. RTS. DIV., In-
        vestigation of Alabama’s State Prisons for Men, at 1 (Apr. 2, 2019),
        https://perma.cc/EY9R-TLL3. Its investigation into sexual abuse
        by corrections officers was ongoing at the time of publication, 
id.
        at 1 n.2, but the DOJ report documented an overall “pattern of un-
        deterred systemic sexual abuse in Alabama prisons,” id. at 35. The
        DOJ also found that the ADOC’s investigations into sexual abuse
        were “incomplete” and “inadequate.” Id. at 41.
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        12                          ABUDU, J., Dissenting                      22-11738

                A review of the ADOC’s Survey of Sexual Victimization
        Data corroborates the DOJ’s finding. The ADOC’s data reveal that
        its own investigations almost never sustain complaints of sexual
        abuse. For example, in its Survey of Sexual Victimization data for
        2015, the ADOC reported substantiating only three out of sixty-
        three allegations of “staff sexual misconduct” 4 and none of the
        twenty-four reports of “staff sexual harassment.”5 ADOC, Survey of
        Sexual Victimization 4-5 (2015), https://perma.cc/3EWX-WTGC.
        Similarly, in 2017, the ADOC reported substantiating none out of
        sixty-eight allegations of “staff sexual misconduct” and none of the
        thirty-five reports of “staff sexual harassment.” ADOC, Survey of
        Sexual Victimization 4-5 (2017), https://perma.cc/GT7L-3RR2.
        The same pattern continued in the years that followed. See, e.g.,
        ADOC, Survey of Sexual Victimization 4-5 (2018),
        https://perma.cc/LG9Q-4XW6 (substantiating one out of twenty-
        three reports of staff sexual misconduct and zero out of seven re-
        ports of staff sexual harassment); ADOC, Survey of Sexual Victimiza-
        tion 4-5 (2019), https://perma.cc/A25C-5YXW (substantiating one
        out of sixty-three reports of staff sexual misconduct and zero out of



        4 “Staff sexual misconduct” includes “[i]ntentional touching, either directly or
        through the clothing, of the genitalia, anus, groin, breast, inner thigh, or but-
        tocks that is unrelated to official duties or with the intent to abuse, arouse, or
        gratify sexual desire” toward an inmate by an employee. ADOC, Survey of
        Sexual Victimization 4 (2015), https://perma.cc/3EWX-WTGC.
        5 “Staff sexual harassment” includes “[r]epeated verbal statements, comments
        or gestures of a sexual nature to an inmate by an employee[.]” Id.
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        22-11738                ABUDU, J., Dissenting                       13

        thirty-two reports of staff sexual harassment). It is against this
        backdrop that Smart filed his grievance.
           III. STANDARD OF REVIEW
               We review a district court’s grant of summary judgment de
        novo, Christmas v. Harris County, 
51 F.4th 1348, 1353
 (11th Cir. 2022),
        crediting the specific facts pled in Smart’s sworn complaint and
        drawing all reasonable inferences in the light most favorable to
        him, Sconiers v. Lockhart, 
946 F.3d 1256, 1262
 (11th Cir. 2020).
        “Summary judgment is warranted where the evidence in the rec-
        ord presents no genuine issue of material fact and compels judg-
        ment as a matter of law in favor of the moving party.” Marbury v.
        Warden, 
936 F.3d 1227, 1232
 (11th Cir. 2019) (quoting Caldwell v.
        Warden, 
748 F.3d 1090, 1098
 (11th Cir. 2014) (internal quotation
        marks omitted).
           IV. DISCUSSION
                On appeal, Smart challenges the district court’s decision to
        grant summary judgment in Defendants’ favor based on qualified
        immunity. First, he argues that Defendants acted outside of their
        discretionary authority when they issued him a disciplinary report
        for lying about his alleged sexual assault. Second, he contends that
        even if Defendants’ conduct involved discretionary functions, they
        violated his clearly established right to file a grievance free from
        retaliation.
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        14                     ABUDU, J., Dissenting                22-11738

                  A. Defendants Acted Outside the Scope of Their Discretionary
                     Authority.
                To invoke the defense of qualified of immunity, Defendants
        initially bear the burden of establishing that they were “(a) per-
        forming a legitimate job-related function (that is, pursuing a job-
        related goal), (b) through means that were within [their] power to
        utilize.” Holloman ex rel. Holloman v. Harland, 
370 F.3d 1252, 1265
        (11th Cir. 2004).
                To answer the first part of that test, our precedent requires
        that we ask, in a more general way, what the job-related function
        entails. See, e.g., 
id. at 1267
 (reasoning that defendant teacher’s
        classroom behavior while disciplining students was part of her dis-
        cretionary duty even if the challenged behavior might have been
        unconstitutional); Sims v. Metro. Dade County, 
972 F.2d 1230
, 1236
        (11th Cir. 1992) (explaining that question of whether defendant
        county could discipline employees for their off-duty conduct was
        distinct from whether off-duty conduct for which employee was
        disciplined was constitutionally protected); Rich v. Dollar, 
841 F.2d 1558, 1564
 (11th Cir. 1988) (distinguishing between the issue of
        whether state attorney’s investigator had discretionary authority to
        prepare and submit probable cause affidavits and whether actual
        probable cause existed for the affidavit).
               Temporarily setting aside the unconstitutional nature of De-
        fendants’ behavior against Smart, disciplining inmates for violating
        prison regulations is unquestionably part of a correctional officer’s
        job description. Defendants meet the first part of the discretionary
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        22-11738                ABUDU, J., Dissenting                        15

        function test because disciplining inmates is something that, “but
        for the alleged constitutional infirmity, would have fallen with[in]
        [Defendants’] legitimate job description.” See Holloman, 
370 F.3d at 1266
.
                The problem for England, Malone, and Baker, however, is
        that a job-related function—in this case, England’s disciplinary re-
        port, Baker’s investigation, and Malone’s punishment—cannot be
        exercised for an illegal purpose or through illegal means. Because
        AR 454 and PREA’s national standards prohibit the very conduct in
        which Defendants engaged in response to Smart’s grievance, De-
        fendants’ decision to charge, investigate, and punish Smart was not
        for a legitimate, lawful reason. Nor was it done through legitimate,
        lawful means.
               AR 454 states that a person who is in custody and has re-
        ported sexual abuse “shall not be issued a disciplinary report for lying
        based solely on the fact that their allegations were unfounded.” Ala.
        Dep’t of Corr. Admin. Reg. 454, § V(H)(2)(c) (emphasis added).
        Yet, England issued Smart “a disciplinary report for lying based
        solely on the fact that [Smart’s] allegations were unfounded.” See
        id. Any suggestion that a subsequent hearing, where identical evi-
        dence from the I&I investigation was introduced, somehow con-
        verted Defendants’ conduct into lawful behavior is simply not plau-
        sible. Issuing an unlawful disciplinary report, which resulted in an
        unlawful hearing, that concluded with an unlawful punishment
        were acts outside of England, Malone, and Baker’s discretionary
        authority. See Holloman, 370 F.2d at 1283 (ruling teacher acted
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        16                      ABUDU, J., Dissenting                22-11738

        outside of her discretionary authority when she pursued the job-
        related goal of “fostering her students’ character education”
        through classroom prayer because prayer was not a means availa-
        ble to teachers to further their pedagogical duties); see also Spencer
        v. Benison, 
5 F.4th 1222, 1231
 (11th Cir. 2021) (finding that defendant
        sheriff was acting within “means that were within his power to uti-
        lize” when he verbally ordered the plaintiff to remove cones and
        vehicles, and the plaintiff had not argued verbal orders were beyond
        his power to use); Sims, 972 F.2d at 1236 (noting that defendant em-
        ployers acted within the scope of their discretionary authority be-
        cause “[t]here [was] no contention that the three-day suspension
        imposed upon the plaintiff employee exceeded the scope of the
        [their] authority to administer disciplinary measures”). For these
        reasons, England, Malone, and Baker are not entitled to qualified
        immunity.
                  B. Defendants’ Retaliatory Behavior Violated Smart’s First
                     Amendment Rights, and His First Amendment Rights
                     Were Clearly Established.
               Because Defendants were not acting within the scope of
        their discretionary authority, the qualified immunity analysis could
        end there. However, even assuming Defendants had overcome
        the discretionary authority bar, their actions against Smart for filing
        a grievance were still retaliatory in nature, thus violating his First
        Amendment rights. See McDonough v. Garcia, 
90 F.4th 1080, 1097
        (11th Cir. 2024) (explaining that if an official was acting within his
        discretionary authority, a plaintiff may still overcome qualified im-
        munity by establishing a violation of a clearly established right). In
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        22-11738                ABUDU, J., Dissenting                        17

        this case, the retaliation was England’s disciplinary report, Baker’s
        disciplinary proceedings, and Malone’s decision to punish him by
        placing him in isolation for thirty days and restrict his contact with
        the outside world. See Boxer X v. Harris, 
437 F.3d 1107, 1112
 (11th
        Cir. 2006), abrogated in part on other grounds by Wilkins v. Gaddy, 
559 U.S. 34
 (2010) (per curiam) (holding that plaintiff’s claim “that he
        was punished for complaining through the established grievance
        system about his treatment by [a prison guard]” was sufficient to
        state a First Amendment retaliation claim).
               The law is clear that public officials are not entitled to qual-
        ified immunity “when they exercise power irresponsibly,” even
        when engaged in a discretionary function. Pearson v. Callahan, 
555 U.S. 223, 231
 (2009). Defendants, as prison officials, enjoy some
        discretion when deciding to punish inmates, but that punishment
        cannot be in response to an incarcerated person complaining about
        his prison conditions, especially given the heightened protections
        that PREA and AR 454 guarantee.
                          i. Defendants’ Acts Were Retaliatory in Nature.
               When an incarcerated person files a grievance to complain
        about the conditions of his confinement, the First Amendment for-
        bids prison officials from punishing that person based solely on that
        grievance. Douglas v. Yates, 
535 F.3d 1316, 1321
 (11th Cir. 2008)
        (“We have explained that ‘First Amendment rights to free speech
        and to petition the government for a redress of grievances are vio-
        lated when a prisoner is punished for filing a grievance concerning
        the conditions of his imprisonment.’” (quoting Boxer X, 437 F.3d at
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        18                      ABUDU, J., Dissenting                 22-11738

        1112)). Moreover, Congress, through PREA’s national standards,
        provided even greater protection for those whose grievances are
        related to alleged instances of sexual assault. See 
28 C.F.R. §§ 115.51
(a), 115.67.
                Smart’s First Amendment claim is a retaliation claim prem-
        ised on Defendants’ acts after he accused England of fondling his
        penis and scrotum in an inappropriate way. For Smart to prevail
        on this claim, he must satisfy three elements. First, he must show
        he had a constitutional right to file his grievance. Bennett v. Hendrix,
        
423 F.3d 1247, 1250
 (11th Cir. 2005). Second, he must show De-
        fendants’ disciplinary report, investigation, and punishment would
        likely deter “a person of ordinary firmness” from filing future
        PREA-related grievances. See 
id. at 1251
 (“An objective standard
        for [the ‘ordinary firmness’ test] provides notice to government of-
        ficials of when their retaliatory actions violate a plaintiff’s First
        Amendment rights.”). Third, he must show Defendants’ actions
        were directly caused or motivated by Smart filing his grievance. See
        
id. at 1250
. The evidence in the record supports a finding that
        Smart has satisfied all three prongs.
                First, Smart’s protected activity was the filing of his griev-
        ance which, after a protracted investigation, was determined to be
        unfounded. See Smith v. Mosley, 
532 F.3d 1270, 1276
 (11th Cir. 2008)
        (“It is an established principle of constitutional law that an inmate
        is considered to be exercising his First Amendment right of free-
        dom of speech when he complains to the prison’s administrators
        about the conditions of his confinement.”); Boxer X, 437 F.3d at
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        22-11738                ABUDU, J., Dissenting                      19

        1112 (“First Amendment rights to free speech and to petition the
        government for a redress of grievances are violated when a pris-
        oner is punished for filing a grievance concerning the conditions of
        his imprisonment.”).
               Second, Defendants’ response to Smart’s grievance was to
        issue him a disciplinary report, institute disciplinary proceedings to
        investigate him for lying, and then punish him by placing him in
        disciplinary segregation and stripping away his canteen, visiting,
        and telephone privileges for thirty days. Smart, and any other per-
        son of “ordinary firmness” who is incarcerated and who experi-
        enced any form of sexual misconduct, especially by guards, would
        be dissuaded from filing a similar grievance. See Mosley, 
532 F.3d at 1275
 & n.10, 1277 (finding that the plaintiff demonstrated the sec-
        ond element of a retaliation claim when he was sentenced to,
        among other things, forty-five days of disciplinary segregation);
        Wildberger v. Bracknell, 
869 F.2d 1467, 1468
 (11th Cir. 1989) (per cu-
        riam) (finding retaliation claim where plaintiff alleged he was
        placed in disciplinary segregation as punishment).
                 Finally, Smart can satisfy the causation element as well—
        England charged Smart with lying based on Smart’s “unfounded”
        grievance. The cascading consequences for Smart all derived from
        him speaking out against sexual assault. See Moton v. Cowart, 
631 F.3d 1337, 1341
 (11th Cir. 2011) (finding that the record, on sum-
        mary judgment, supported a causal connection between the plain-
        tiff’s grievance and the discipline the correctional officer imposed).
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        20                      ABUDU, J., Dissenting                22-11738

               Defendants also argue that O’Bryant v. Finch, 
637 F.3d 1207
        (11th Cir. 2011), forecloses Smart’s First Amendment claim be-
        cause his punishment was based on an actual finding that he vio-
        lated a prison regulation by lying about the sexual assault. How-
        ever, O’Bryant actually buttresses—rather than undermines—
        Smart’s retaliation claim and strengthens Smart’s causation argu-
        ment.
                In O’Bryant v. Finch, the incarcerated plaintiff O’Bryant filed
        a First Amendment retaliation claim under 
42 U.S.C. § 1983
 against
        two prison guards who had issued him disciplinary reports after he
        filed grievances claiming that he received an inadequate consulta-
        tion regarding prison rules. 
Id. at 1209
. Weeks after O’Bryant filed
        his consultation-related grievances, a guard issued him a discipli-
        nary report for “disrespect” after he called the guard “ignorant” and
        “fucking retarded.” 
Id. at 1210
. Three days later, another guard
        issued O’Bryant a second disciplinary report for “disrespect” when
        he refused to back away from his cell door as directed during an
        emergency happening in another cell. 
Id. at 1211
. Notably, the
        actual basis for the two disciplinary reports, other than O’Bryant’s
        allegation that they were a form of retaliation, had nothing to do
        with the specific subject matter of O’Bryant’s grievances. See 
id. at 1210,1211
. The panel affirmed summary judgment in the defend-
        ants’ favor because there was sufficient evidence to support the dis-
        ciplinary panel’s finding that O’Bryant was disrespectful and failed
        to obey the guards’ commands and, thus, had violated prison reg-
        ulations. See 
id. at 1215
. In reaching this conclusion, the panel held
        that, “an inmate cannot state a claim of retaliation for a disciplinary
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        22-11738                ABUDU, J., Dissenting                       21

        charge involving a prison rule infraction when the inmate was
        found guilty of the actual behavior underlying that charge.” See 
id. at 1215
. The panel also affirmed summary judgment because
        O’Bryant had failed to show “a causal connection between his ear-
        lier grievances and the disciplinary harm” he experienced. 
Id.
                With respect to the causal connection issue in O’Bryant, the
        panel relied on Smith v. Mosley and Moton v. Cowart, which both in-
        volved inmates who claimed that prison officials had retailed
        against them for filing grievances. The plaintiff in Mosley could not
        satisfy the causal connection element because the discipline he re-
        ceived was based on comments that he made in a letter to the DOJ
        that included false statements and were, thus, unprotected speech.
        
532 F.3d at 1276
. In setting forth the defendants’ burden of proof
        as it related to causation, the Mosley court held that, “if the defend-
        ant can show that he would have taken the same action in the ab-
        sence of the protected activity, he is entitled to prevail on his mo-
        tion for summary judgment.” 
Id.
 at 1278 (quoting Thaddeus-X v.
        Blatter, 
175 F.3d 378, 399
 (6th Cir. 1999)). Because the correctional
        officers would have proceeded as they did despite the grievances
        the plaintiff had lodged, the plaintiff could not meet the causational
        element. Id. at 1279. Here, Defendants have not shown, nor could
        they, that they would have taken the same action against Smart in
        the absence of his protected activity because the very purpose of
        the punishment was the protected activity.
             In Moton, however, we reversed the district court’s grant of
        summary judgment, ruling that there was a genuine issue of
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        22                      ABUDU, J., Dissenting                22-11738

        material fact as to the motivation behind the prison’s decision to
        discipline the plaintiff. 
631 F.3d at 1342-43
. In that case, the prison
        guard issued two disciplinary reports immediately after receiving
        Moton’s grievance on the grounds that the language in the griev-
        ance—which was written in all capital letters—was disrespectful
        and Moton’s statement that he was going to contact his attorney in
        response to the first grievance was threatening. 
Id. at 1340-41
. In
        finding that no prison rule was violated, this Court specifically held
        that an inmate’s statement that he plans to call his attorney does
        not constitute a punishable “‘spoken threat,’” and that “using large
        and upper case letters in a grievance,” in and of itself, does not vio-
        late the prison rule prohibiting disrespect. 
Id. at 1342
. Thus, be-
        cause no prison rule had been violated, Moton had created a ques-
        tion of fact as to whether the disciplinary reports were actually
        based on the filing of his grievance. 
Id. at 1342-43
. Here too, as
        further explained below, the lack of evidence against Smart demon-
        strates no prison rule was violated.
               O’Bryant also emphasized the importance of due process
        protections for inmates going through a disciplinary hearing pro-
        cess. Specifically, there must be “some evidence in the record” to
        support the disciplinary panel’s findings, i.e. “some basis in fact.”
        O’Bryant, 
637 F.3d at 1214
 (quoting Superintendent v. Hill, 
472 U.S. 445, 455-57
 (1985) (ruling that a record cannot be “so devoid of ev-
        idence that the findings of the disciplinary board were without sup-
        port or otherwise arbitrary”)).
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        22-11738               ABUDU, J., Dissenting                    23

               In Smart’s case, there was no evidence to support England’s
        charge and the ultimate finding that Smart lied about England sex-
        ually assaulting him; even Defendants’ counsel during oral argu-
        ment admitted that the prison’s written findings were “sparse” at
        best. The only evidence upon which Baker relied in finding that
        Smart lied was (1) England’s sworn testimony and (2) Bynum’s con-
        clusion that Smart’s grievance was “unfounded.” There was abso-
        lutely nothing in Bynum’s I&I report or Baker’s disciplinary report
        explaining why they did not credit Smart’s testimony; why they did
        not believe the testimony of Franky Johnson or Timothy Gayle,
        the two inmates who had a direct line of vision to the incident and
        stated under oath that they saw England grab Smart’s penis; or why
        they did not credit correctional officer Smith who corroborated
        hearing Smart contemporaneously scream out when England fon-
        dled him. While some deference is due to Baker and Bynum, it is
        very troubling and surprising that neither referenced any evidence
        supporting Smart’s version of events.
               Moreover, England conceded that he placed his hands on
        Smart’s penis and scrotum, and the rest of the evidence introduced
        by Smart at the disciplinary hearing was unchallenged and unim-
        peached. England never objected to Smith’s testimony that Smart
        yelled out as the search was happening, and he did not present any
        evidence questioning Johnson and Gayle’s line of sight. Thus,
        while Bynum concluded that England’s genital search might not
        have amounted to sexual assault, there is absolutely nothing in the
        record to support a finding that Smart lied about it. Because an
        “unfounded” determination under AR 454 could not serve as the
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        24                      ABUDU, J., Dissenting                 22-11738

        basis for issuing a disciplinary report against Smart for lying, it def-
        initely could not support a conviction for lying or the punishment
        that Smart received based on England’s accusation. See O’Bryant,
        
637 F.3d at 1215
.
                Finally, the O’Bryant court’s deference to disciplinary find-
        ings does not apply here. O’Bryant explained that a court’s failure
        to defer to such findings “would render the prison disciplinary sys-
        tem impotent by inviting prisoners to petition the courts for a full
        retrial each time they are found guilty of an actual disciplinary in-
        fraction after having filed a grievance.” O’Bryant, 
637 F.3d at 1216
        (emphasis omitted). However, the correctional officers in O’Bryant
        were not prohibited from charging O’Bryant with disrespecting a
        guard because there was some evidence in the record to support a
        finding that O’Bryant uttered those disrespectful statements.
        Smart’s circumstances are profoundly different. The deference ra-
        tionale does not apply when the disciplinary process should have
        never been utilized in the first place. Indeed, AR 454, § V(H)(2)(c)
        was specifically promulgated so that officials who flout prison reg-
        ulations cannot punish or otherwise retaliate against inmates who
        report sexual abuse, even when those complaints are later deter-
        mined to be unfounded. In contravention of AR 454, England’s
        disciplinary report was a direct response to Smart’s grievance and
        there is nothing in the record to suggest that, absent Smart’s formal
        grievance, England would have charged Smart with lying. See Mos-
        ley, 
532 F.3d at 1278
 (emphasizing that the defendant bears the bur-
        den of proving “he would have taken the same action in the ab-
        sence of the protected activity” (quoting Thaddeus-X, 175 F.3d at
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        22-11738                ABUDU, J., Dissenting                        25

        399)). The findings from Baker’s subsequent disciplinary proceed-
        ing—which did not entertain any new evidence—cannot shield De-
        fendants from Smart’s retaliation claim.
                         ii. Smart’s First Amendment Right was Clearly Estab-
                             lished.
                 Under our precedent, a right can be clearly established in
        one of three ways: “(1) case law with indistinguishable facts, (2) a
        broad statement of principle within the Constitution, statute, or
        case law, or (3) conduct so egregious that a constitutional right was
        clearly violated, even in the total absence of case law.” Crocker v.
        Beatty, 
995 F.3d 1232, 1240
 (11th Cir. 2021) (citing Lewis v. City of W.
        Palm Beach, 
561 F.3d 1288, 1291-92
 (11th Cir. 2009) (internal quota-
        tion marks omitted)). “A right is ‘clearly established’ if controlling
        law gave the official ‘fair warning’ that his conduct violated that
        right.” Nelson v. Tompkins, 
89 F.4th 1289, 1299
 (11th Cir. 2024) (cita-
        tion and internal quotation marks omitted).
                Decades of Eleventh Circuit case law with materially similar
        facts provided Defendants fair notice that their conduct violated
        Smart’s First Amendment right to be free from retaliation for filing
        a grievance. In 1985, we decided Bridges v. Russell, 
757 F.2d 1155
        (11th Cir. 1985). In Bridges, we held as a matter of first impression
        that the plaintiff, an incarcerated person, had alleged a First
        Amendment violation by claiming that prison officials transferred
        him to another institution as punishment after he, among other
        acts, filed a grievance concerning racial discrimination in work as-
        signments. 
757 F.2d at 1156-57
. One year later we decided Wright
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        26                       ABUDU, J., Dissenting                 22-11738

        v. Newsome, 
795 F.2d 964
 (11th Cir. 1986). In Newsome, we held that
        an incarcerated person had successfully alleged a First Amendment
        claim when he asserted prison officials retaliated against him by
        searching his cell and seizing his property for filing administrative
        grievances. 
795 F.2d at 968
. Several years later, in Wildberger, this
        Court—relying on Bridges and Wright—explained: “It seems clear
        that if appellant is able to establish that his discipline was the result
        of his having filed a grievance concerning the conditions of his im-
        prisonment, he will have raised a constitutional issue, under the
        authority of these cases.” 
869 F.2d at 1468
.
                We have continued to decide materially similar cases estab-
        lishing that Defendants’ conduct violated Smart’s First Amend-
        ment right to be free from retaliation. See Mosley, 
532 F.3d at 1276
        (explaining that the First Amendment right of freedom of speech
        to complain about conditions of confinement is well established);
        Moton, 
631 F.3d at 1343
 (“It is well established that a prison inmate
        retains those First Amendment rights that are not inconsistent with
        his status as a prisoner or with the legitimate penological objectives
        of the corrections system.” (internal quotation marks and citation
        omitted)). We have even done so in the context of an inmate re-
        porting sexual abuse by a correctional officer. In Boxer X, for exam-
        ple, an incarcerated individual sued a correctional officer for pun-
        ishing him after he complained about her forcing him to repeatedly
        expose himself to her and to perform sexual acts for her gratifica-
        tion. 
437 F.3d at 1112
. We reversed the district court’s dismissal of
        the plaintiff’s claims because he had stated a claim for retaliation
        under the First Amendment. 
Id.
 These cases all demonstrate that
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        22-11738                 ABUDU, J., Dissenting                          27

        the law clearly established the unconstitutionality of Defendants’
        conduct. Defendants cannot benefit from the shield of qualified
        immunity by arguing the law was not clearly established.
                Bridges, Wright, and several other cases also establish a
        broad, clearly established principle that governs the facts of Smart’s
        situation. See Loftus v. Clark-Moore, 
690 F.3d 1200, 1204
 (11th Cir
        2012) (explaining that a plaintiff may rely on a “broader, clearly es-
        tablished principle [that] should control the novel facts [of the] sit-
        uation) (citation and internal quotation marks omitted)). These
        cases stand for the proposition that officers may not retaliate
        against inmates for filing grievances about the conditions of their
        confinement, and this rule applies with “obvious clarity” to the
        facts of this case. See 
id. at 1205
; see also Hope v. Pelzer, 
536 U.S. 730, 741
 (2002) (a “constitutional rule already identified in the decisional
        law may apply with obvious clarity to the specific conduct in ques-
        tion”).
                We have previously invoked this constitutional principle to
        deny qualified immunity in a wide range of retaliation cases. In
        Bennett, for example, we denied qualified immunity to sheriff’s dep-
        uties who intimidated, attempted to arrest, and engaged in other
        acts of harassment against private citizens for supporting a county
        referendum that proposed diminishing the power of the sheriff’s
        department. 
423 F.3d at 1255-56
. In rejecting the deputies’ quali-
        fied immunity defense, we explained that our precedent and Su-
        preme Court precedent has “long held that state officials may not
        retaliate against private citizens because of the exercise of their
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        28                      ABUDU, J., Dissenting                22-11738

        First Amendment rights.” 
Id. at 1255
. Therefore, this constitu-
        tional rule applied with “obvious clarity” to the specific facts of the
        case and defeated qualified immunity. 
Id. at 1255-56
.
               This prohibition on retaliation based on protected First
        Amendment speech and conduct was invoked again in Bailey v.
        Wheeler, 
843 F.3d 473
 (11th Cir. 2016). In Bailey v. Wheeler, Officer
        Bailey of the Douglasville Police Department filed a written com-
        plaint reporting his colleagues and officers in the Douglas County
        Sheriff’s Office for racial profiling and other constitutional viola-
        tions. 
843 F.3d at 477
. In response, the Douglasville Police Depart-
        ment fired him. 
Id. at 479
. After he appealed his termination, a
        Major with the Douglas County Sheriff’s Office, Tommy Wheeler,
        put out an alert to law enforcement that permitted “all Douglas
        County law-enforcement officers a reasonable basis for using
        force—including deadly force—against Bailey.” 
Id. at 482
. In re-
        jecting Wheeler’s qualified immunity defense, we relied on the
        “reasoning . . . and the broad principle” articulated in Bennett,
        which put Wheeler on notice that his behavior would violate Bai-
        ley’s First Amendment rights. 
Id. at 484
.
                Thus, the general proposition that correctional officers may
        not retaliate against prisoners for filing grievances has been well
        established in the Eleventh Circuit starting from 1985. See Bridges,
        
757 F.2d at 1156
; see also Wright, 
795 F.2d at 968
 (recognizing that
        retaliation for filing lawsuits and administrative grievances violates
        “the inmate’s First Amendment rights”). Protection against retali-
        ation for filing a grievance about sexual abuse at the hands of a
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        22-11738                 ABUDU, J., Dissenting                          29

        correctional officer certainly falls directly within that general prop-
        osition and applies with obvious clarity to Smart’s case.
               PREA, its regulations, and AR 454 reinforce the obviousness
        of Defendants’ First Amendment violation. The PREA regulations,
        promulgated pursuant to federal statute, specifically provide for
        protection against retaliation. See, e.g., 
28 C.F.R. § 115.67
(a) (“The
        [prison or jail] shall establish a policy to protect all inmates and staff
        who report sexual abuse or sexual harassment or cooperate with
        sexual abuse or sexual harassment investigations from retaliation
        by other inmates or staff . . . .”); 
id.
 § 115.67(b) (“The [prison or jail]
        shall employ multiple protection measures, such as housing
        changes or transfers for inmate victims or abusers, removal of al-
        leged staff or inmate abusers from contact with victims, and emo-
        tional support services for inmates or staff who fear retaliation for
        reporting sexual abuse or sexual harassment or for cooperating
        with investigations.”).
               If these federal standards were not enough to place Defend-
        ants on notice, AR 454 itself prohibits retaliation against inmates
        for reporting sexual abuse. See, e.g., AR 454 § V(K)(1) (“Retaliation
        in any form for the reporting of, or cooperation with, sexual abuse
        or harassment allegations is strictly prohibited.”); id. § V(K)(2)
        (“The Warden and [Institutional PREA Compliance Manager] shall
        ensure inmates and staff who report sexual abuse, sexual harass-
        ment, or cooperate with a sexual abuse investigation are protected
        from retaliation by other inmates or staff.”). Although prison reg-
        ulations themselves do not constitute constitutional law, they
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        30                      ABUDU, J., Dissenting                 22-11738

        certainly “undermine any claim by defendants that they were una-
        ware of their legal obligations” not to retaliate. See Al-Amin v.
        Smith, 
511 F.3d 1317
, 1336 n.37 (11th Cir. 2008). Importantly, this
        is not a case where Smart is arguing there is some obscure, un-
        known state regulation that prohibits Defendants’ conduct. This is
        a case where there is clear Eleventh Circuit precedent prohibiting
        retaliation based on filing a grievance, federal regulations that pro-
        hibit retaliation based on a report of sexual abuse, and a state regu-
        lation forbidding the same. Moreover, AR 454 was specifically
        promulgated to comply with PREA and PREA-based national
        standards. Given these judicial authorities, statutory authorities,
        and regulatory authorities, the “salient question,” of whether De-
        fendants had fair warning that their conduct was unconstitutional,
        can only be answered with a resounding “yes.” See Hope, 
536 U.S. at 731
 (explaining that in determining whether a right was clearly
        established, the “salient question . . . is whether the state of the law
        . . . gave [the officers] fair warning that [their] alleged treatment of
        [the plaintiff] was unconstitutional.”).
             V. CONCLUSION
                The power imbalance between incarcerated individuals and
        correctional officers is clear. Recognizing this very power dy-
        namic, Congress acknowledged that “[p]rison rape often goes un-
        reported,” 
34 U.S.C. § 30301
(6), because of the widespread fear of
        retaliation. Smart had nothing to gain by lying and everything to
        lose by reporting England. Despite this risk, which manifested into
        reality, Smart chose to speak out and was punished for doing so.
        There can be no clearer, straightforward violation of the First
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        22-11738               ABUDU, J., Dissenting                    31

        Amendment right to file a grievance free from retaliation than this
        case.
              For these reasons, I respectfully dissent.


Reference

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