Black v. Dolan
In brief
The Supreme Court refused to hear Black v. Dolan, so it did not decide whether inmate retaliation claims require actual chill or ordinary firmness.
- Where it stands
- Decided
Decided · May 4, 2020
- What it’s about
- This case involves a petition for a writ of certiorari filed in the Supreme Court following a decision by the United States Court of Appeals for the First Circuit.
- Who it affects
- The denial gave Black and Dolan no Supreme Court decision on which test applies to Black’s inmate retaliation claim.
Summary: written with AI from the case record.

What it's about
Specific details regarding the underlying legal dispute are not available in the provided record.
The case came from the First Circuit and focused on what an inmate must show to pursue a First Amendment retaliation claim.
Question presented
1. Whether the Second Circuit’s "actual chill" requirement for First Amendment retaliation claims brought by inmates conflicts with the "ordinary firmness" standard used by other Circuits and this Court’s precedent? 2. Whether the Second Circuit’s requirement that an inmate demonstrate an "actual chill" of his First Amendment rights to maintain a retaliation claim is consistent with the "ordinary firmness" test set forth in Turner v. Safley, 482 U.S. 78 (1987)?
What the Court decided
Holding
Petition DENIED.
What's next
The Supreme Court’s action on this petition is finished. No further Supreme Court step is identified.
Documents
Opinions
Key filings
Docket activity
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
More questions
- When did the Supreme Court deny review in Black v. Dolan?
- The Court denied the petition on May 4, 2020.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.