Free Speech

Case - 511 U.S. 661

Parties: Waters v. Churchill

Date: 1994-05-31

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Paragraph: 40 - "Our 'profound national commitment' to the freedom of speech," post, at 699 (STEVENS, J., dissenting), must of necessity operate differently when the government acts as employer rather than sovereign.

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  • (is) access to government benefits

Phrase match: the freedom of speech," post, at

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Paragraph: 53 - I do not doubt that the First Amendment contains within it some procedural prescriptions -- that in some circumstances, "the freedom of speech" recognized by the Constitution consisted of a right to speak unless and until certain procedures to prevent the speech had first been complied with.

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  • (reg) procedural prescriptions

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Paragraph: 67 - N285* Every American has the right to express an opinion on issues of public significance. In the private sector, of course, the exercise of that right may entail unpleasant consequences. Absent some contractual or statutory provision limiting its prerogatives, a private-sector employer may discipline or fire employees for speaking their minds. The First Amendment, however, demands that the government respect its employees' freedom to express their opinions on issues of public importance.

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  • N285* / / / / Federal employees may not be punished for their speech, even though private sector employees may

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  • (is) expression of opinions

Phrase match: the right to express an opinion

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Paragraph: 23 - Government employee speech must be treated differently with regard to procedural requirements as well. > For example, speech restrictions must generally precisely define the speech they target. Baggett v. Bullitt, 377 U.S. 360, 367-368, 12 L. Ed. 2d 377, 84 S. Ct. 1316 (1964); Hustler Magazine, Inc. v. Falwell, 485 U.S. 46, 55, 99 L. Ed. 2d 41, 108 S. Ct. 876 (1988). Yet surely a public employer may, consistently with the First Amendment, prohibit its employees from being "rude to customers," a standard almost certainly too vague when [**1887] applied to the public at large.

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  • (reg) speech of public employees

Phrase match: Government employee speech must be treated

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Paragraph: 71 - A First Amendment claimant need not allege bad faith; the controlling question is not the regularity of the agency's investigative procedures, or the purity of its motives, [**1900] but whether the employee's freedom of speech has been "abridged."

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  • (reg) Workplace Speech

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Paragraph: 47 - I join JUSTICE O'CONNOR's plurality opinion stating that, under the Free Speech Clause, a public employer who reasonably believes a third-party report that an employee engaged in constitutionally unprotected speech may punish the employee in reliance on that report, even if it turns out that the employee's actual remarks were constitutionally protected. I add these words to emphasize that, in order to avoid liability, the public employer must not only reasonably investigate the third-party report, but must also actually believe it.

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  • (is not) Unprotected Speech and Employers

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Paragraph: 49 - A public employer who did not really believe that the employee engaged in disruptive or otherwise punishable speech can assert no legitimate interest strong enough to justify chilling protected expression, whether the employer affirmatively disbelieved the third-party report or merely doubted its accuracy. Imposing liability on such an employer respects the N211* "longstanding recognition that the First Amendment's primary aim is the full protection of speech upon issues of public concern, as well as the practical realities involved in the administration of a government office."

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  • N211* / quote / endorsement / Q0506 /

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  • (why is) Speech Punishable by Employers

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Paragraph: 14 - There is no dispute in this case about when speech by a government employee is protected by the First Amendment: To be protected, the speech must be on a matter of public concern, and the employee's interest in expressing herself on this [***695] matter must not be outweighed by any injury the speech could cause to N212* "'the interest of the State, as an employer, in promoting the efficiency of the public services it performs through its employees.'"

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  • N212* / quote / endorsement / Q0221 /

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  • (why is) Employee Speech on Issues of Public Concern

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Paragraph: 17 - These cases establish a basic First Amendment principle: Government action based on protected speech may under some circumstances violate the First Amendment even if the government actor honestly believes the speech is unprotected. And though JUSTICE SCALIA suggests that this principle be limited to licensing schemes and to "deprivation[s] of the freedom of speech specifically through the judicial process," post, at 687 (emphasis in original), we do not think the logic of the cases supports such a limitation. Speech can be chilled and punished by administrative action as much as by judicial processes; in no case have we asserted or even implied the contrary.

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  • () Government Limitations on Protected Speech

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Paragraph: 42 - And under the Connick test, Churchill's speech as reported by Perkins-Graham and Ballew was unprotected. Even if Churchill's criticism of cross-training reported by Perkins-Graham and Ballew was speech on a matter of public concern -- something we need not decide -- the potential disruptiveness of the speech as reported was enough [***703] to outweigh whatever First Amendment value it might have had.

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  • (is not) Disruptive Employee Speech

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Paragraph: 68 - Given the posture in which this case comes to us, we must assume that Churchill's statements were fully protected by the First Amendment. Nevertheless, the plurality concludes that a dismissal for speech is valid as a matter of law as long as the public employer reasonably believed that the employee's speech was protected. See ante, at 677-678. This conclusion is erroneous because it provides less protection for a fundamental constitutional right than the law ordinarily provides for less exalted rights, including contractual and statutory rights applicable in the private sector.

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  • (why is) Speech Critical of an Employer

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