The First Amendment to the United States Constitution protects individuals’ rights to free speech and freedom of religion. As such, the U.S. government is generally not permitted to punish individuals for exercising First Amendment free speech. This includes arrests for criminal activity made by a police officer to retaliate against an individual for their protected speech. Under 42 USC §1983, an individual can bring a civil suit for wrongful arrest, including retaliatory arrest, in violation of their First Amendment rights if there is a “but-for” causal connection between the officer’s retaliatory animus and the individual's speech. Kennedy v. City of Villa Hills, 635 F.3d. 210, 217 (6th Cir. 2011).