A Washington state prisoner brought a pro se civil rights action, seeking a preliminary injunction because the prison officials retaliated against him for filing a previous action regarding his involuntary exposure to secondhand tobacco smoke.  He sought an injunction against his being transferred to another facility and against any further retaliation.  The district court denied his motion for an injunction; the U.S. Court of Appeals for the Ninth Circuit affirmed, ruling that “the transfer’s interference with his pending lawsuits did not cause sufficient hardship to warrant a preliminary injunction.”

1996 U.S. App. LEXIS 8540, 82 F.3d 424.