Gagliardi v. Village of Pawling
In Gagliardi v. Village of Pawling, 18 F.3d 188, 194 (2d Cir. 1994), the Courts of Appeals for the Second Circuit held that "[t]he rights to complain to public officials and to seek administrative and judicial relief are protected by the First Amendment."
The Court upheld a Section 1983 claim against local officials for retaliation against the exercise of First Amendment rights. A claim for inaction by the local officials for enforcing the zoning code was included.