Chism v. Chang, et al. – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the district court's grant of summary judgment because the plaintiff failed to establish a genuine dispute of material fact regarding the elements of his First Amendment retaliation claim.
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: This decision reinforces the high evidentiary burden on prisoners bringing First Amendment retaliation claims, requiring specific proof of adverse actions and improper motive by prison officials.

Chism v. Chang, et al.

June 26, 2026 ·2:20-cv-01072-DJC-DMC ·Unpublished · By Aisha Johnson

The United States Court of Appeals for the Ninth Circuit affirmed a district court's summary judgment in a prisoner's civil rights lawsuit. The court held that the plaintiff failed to present sufficient evidence to support his First Amendment retaliation claims against prison officials.

Background

William H. Chism, III, a California state prisoner, filed a pro se lawsuit under 42 United States Code Section 1983 alleging First Amendment retaliation by prison officials Chang, De La Rosa, Cross, and Domingo. The district court granted summary judgment in favor of the defendants, prompting Chism to appeal to the Ninth Circuit.

The court’s reasoning

The panel reviewed the case de novo and affirmed the district court’s decision. The court concluded that Chism failed to raise a genuine dispute of material fact concerning whether Chang or De La Rosa took adverse actions against him. Additionally, the court found that Chism failed to show that the actions of Cross and Domingo were not taken in furtherance of legitimate penological goals.

What it means going forward

This decision reinforces the high evidentiary burden on prisoners bringing First Amendment retaliation claims, requiring specific proof of adverse actions and improper motive by prison officials.