Do prison inmates have a First Amendment right to include threatening, abusive, and irrelevant language in grievances?

QUESTION PRESENTED Inmates in state and federal prisons file hundreds of thousands of grievances every year, and grievance programs peacefully resolve countless disputes at an administrative level, without litigation. To make these grievance programs more effective and avoid needless tension between inmates and officers, most states and the federal government prohibit abusive, disrespectful, or threatening language in grievances. But the Ninth Circuit has held, in a series of cases, that such restrictions violate the First Amendment. Based on this conclusion, the Ninth Circuit here held that a Washington correctional officer violated an inmate’s clearly established First Amendment rights when he directed the inmate to omit such content. Five other circuits and many state courts have held that similar restrictions are constitutional. The question presented is: Do prison inmates have a First Amendment right to include threatening, abusive, and irrelevant language in grievances? ii PARTIES Petitioner Dennis Dahne was the defendant in the district court and appellant in the court of appeals. He is a Grievance Coordinator for the Washington Department of Corrections at the Stafford Creek Corrections Center. Respondent Thomas W.S. Richey was the plaintiff at the district court and appellee in the court of appeals. He is an inmate in the custody of the Washington Department of Corrections.