Legitimate Penological Interest as a Complete Defense to Prisoner-Retaliation and Class-of-One Claims: Commentary on Reynolds v. Quiros (2d Cir. 2025)

Introduction

The United States Court of Appeals for the Second Circuit, in a non-precedential summary order dated 27 June 2025, affirmed the dismissal of First Amendment retaliation and Fourteenth Amendment “class-of-one” equal protection claims brought by Richard Reynolds, a Connecticut inmate serving a life sentence.

Reynolds had previously secured a major victory in Reynolds v. Quiros, 990 F.3d 286 (2d Cir. 2021) (“Reynolds I”), which invalidated a Connecticut statute governing the post-death-penalty confinement regime. Four days after that victory, prison officials charged him with conspiring to bring contraband into the prison, placed him in restrictive housing, elevated him to “High Security” status, transferred him to different facilities, and seized various personal items. Reynolds alleged that these actions were retaliatory punishment for his successful litigation efforts and that he was singled out for differential treatment without any rational basis.

Judge Stefan R. Underhill in the District of Connecticut granted summary judgment to the prison officials on all claims. On appeal, Reynolds contested only the retaliation and class-of-one rulings. A Second Circuit panel (Judges Lohier, Carney, and Pérez) unanimously upheld the district court’s judgment.

Summary of the Judgment

The Court held that—even assuming Reynolds had established a prima facie case of retaliation—undisputed evidence demonstrated that prison officials would have taken the same disciplinary measures irrespective of Reynolds’s protected litigation activity, thereby defeating the retaliation claims at the summary-judgment stage.

Similarly, for the class-of-one claim, the Court found a rational basis for the disparate treatment: Reynolds’s possession of contraband, participation in a contraband conspiracy, and resultant High Security classification. Consequently, the district court’s judgment was affirmed in full.

Analysis

Precedents Cited and Their Influence

Dolan v. Connolly, 794 F.3d 290 (2d Cir. 2015)
Provided the basic three-part framework for prisoner retaliation claims: (1) protected activity, (2) adverse action, and (3) causal connection.
Graham v. Henderson, 89 F.3d 75 (2d Cir. 1996)
Articulated the “same outcome” defense: even if retaliatory intent exists, defendants avoid liability by proving the same action would have been taken for legitimate reasons.
Hayes v. Dahlke, 976 F.3d 259 (2d Cir. 2020)
Reiterated Graham and emphasized the defendant’s burden to show undisputed facts negating causation.
Vill. of Willowbrook v. Olech, 528 U.S. 562 (2000)
Recognized the “class-of-one” theory of equal protection—differential treatment of a single individual without a rational basis is actionable.
Progressive Credit Union v. City of New York, 889 F.3d 40 (2d Cir. 2018)
Applied Olech and clarified that the presence of any conceivable rational basis defeats a class-of-one claim.
Reynolds v. Quiros, 990 F.3d 286 (2d Cir. 2021)
Reynolds’s earlier victory; relevant because it was the alleged motive for retaliation. However, the Court treated that motive as immaterial given the legitimate security reasons for the later disciplinary measures.

Legal Reasoning of the Court

Undisputed Security Concerns
Reynolds admitted possessing numerous prohibited items—e.g., a screwdriver capable of use as an escape tool, a lighter, a hard drive, excessive medication, and pornography— and acknowledged participating in a contraband conspiracy. These admissions provided an objective, legitimate penological reason for:
- Immediate placement in restrictive housing and subsequent High Security classification;
- Renewal of High Security status in November 2021;
- Transfer to other facilities to separate him from a compromised officer; and
- Confiscation of property approved only at the original facility.
Application of the “Same Outcome” Defense
Relying heavily on Graham and subsequent Second Circuit authority, the Court reasoned that once defendants demonstrated non-retaliatory grounds, the burden shifted back to Reynolds to produce evidence countering those grounds. Reynolds offered speculation rather than concrete facts, so there remained no genuine dispute for trial.
Rational-Basis Review for Class-of-One Claim
Under Olech, Reynolds could prevail only by demonstrating that no rational justification existed for his differential treatment. The Court held that the combination of contraband possession, security classification, and involvement in a conspiracy easily satisfied rational-basis review.

Impact on Future Litigation and Correctional Administration

Although issued as a summary order without precedential force under Second Circuit Local Rule 32.1.1, the decision nonetheless offers persuasive guidance:

Reinforces High Bar for Prisoner Retaliation Claims: Inmates must not only establish a prima facie case but also rebut evidence that the same security action would have occurred absent the protected conduct.
Clarifies Evidentiary Requirements: Conclusory allegations or speculation about pretext will not suffice to defeat summary judgment once officials produce objective, security-related justifications.
Affirms Broad Leeway for Prison Officials: Confiscation of property, facility transfers, and elevated security classifications will withstand constitutional challenge if linked to concrete safety concerns.
Guides Counsel on Litigation Strategy: Plaintiff-inmates must develop affirmative evidence—e.g., comparative data showing others were treated differently— or uncover inconsistencies that genuinely cast doubt on the asserted penological rationale.
Signal to District Courts: Summary disposition is appropriate where undisputed facts show a rational security motive, supporting efficient resolution of similar suits.

Complex Concepts Simplified

Summary Order: A short appellate decision, usually unpublished, that lacks formal precedential value but may be cited under specific rules.

High Security Status: An internal prison designation imposing the most restrictive housing and movement limitations, reserved for inmates posing exceptional risk.

Prima Facie Case: The initial set of facts a plaintiff must prove to proceed; if unrebutted, these facts would justify relief.

“Same Outcome” or Mount Healthy Defense: Even if retaliatory intent exists, defendants avoid liability by proving they would have taken the same action for legitimate reasons.

Class-of-One Claim: An equal-protection theory where a single individual—not a group—alleges intentional, irrational discrimination under the Fourteenth Amendment.

Rational-Basis Review: The most deferential constitutional standard; government action is upheld if any conceivable legitimate purpose exists.

Contraband: Any item whose possession by an inmate is prohibited by prison rules—ranging from tools to electronics to certain medications.

Penological Interest: A legitimate objective related to prison safety, order, discipline, or rehabilitation; courts give great deference to prison officials’ judgments in this area.

Conclusion

Reynolds v. Quiros (2025) underscores a critical principle in prisoner civil-rights litigation: objective evidence of legitimate security concerns is a complete defense to retaliation and class-of-one equal protection claims—even when the inmate has engaged in celebrated, protected litigation against the very officials now disciplining him.

By affirming summary judgment, the Second Circuit reinforced the deference accorded to prison administrators under both the First and Fourteenth Amendments. The decision serves as a practical roadmap for future plaintiffs and defendants alike, highlighting the evidentiary burdens at play and the pivotal role of undisputed facts in resolving constitutional claims arising within the formidable context of prison management. While non-precedential, the order’s reasoning will likely resonate in district courts confronting similar allegations, ensuring that legitimate penological interests remain the decisive factor in assessing claims of unconstitutional retaliation or unequal treatment behind bars.