Hudspeth v Figgins - threat of retaliation actionable - regardless of the success of the threat

Hudspeth v. Figgins, 584 F.2d 1345 (4th Cir. 1978). Stating

Once judicial proceedings have been commenced, the state may not punish a prisoner for having sought judicial remedies. Russell v. Oliver, 552 F.2d 115, 116 (4th Cir. 1977); Haymes v. Montanye, 547 F.2d 188(2d Cir. 1976).

A threat of physical harm to a prisoner if he persists in his pursuit of judicial relief is as impermissible as a more direct means of restricting the right of access to the courts. Nor is it necessary that the prisoner succumb entirely or even partially to the threat. It is enough that the threat was intended to impose a limitation upon the prisoner's right of access to the court and was reasonably calculated to have that effect. See Lingo v. Boone, 402 F.Supp. 768, 775 (N.D.Cal.1975).

DeLoach v. Bevers - No Qualified immunity in deliberate coverup

DeLoach v. Bevers, 922 F.2d 618, 621-23 (10th Cir.1990) (denying qualified immunity to police officer on § 1983 claims in light of deliberate conduct amounting to coverup)

Threat to deny monies if suit is filed

Silver v. Cormier, 529 F.2d 161, 163 (10th Cir.1976) (recognizing right of access claim arising from threat to withhold monies if suit filed)

McKay v Hammock - a threat to retaliate if civil rights claim is filed.

McKay v. Hammock, 730 F.2d 1367, 1375 (10th Cir.1984) (remanding for consideration of right of access claim where state officer threatened retaliation if civil rights claim filed)