context: Under Pickering and its progeny, unless the employee's comments are actually disruptive, single out a specific person as a target, or materially interfere with the performance of an employee's duties, the right to unhampered expression on matters of public salience will prevail.
citation_a.signal: see
citation_a.identifier: 605 F.2d 1058, 1063
citation_a.parenthetical: improper to silence employee who reveals misappropriation of public funds, despite resulting disharmony
citation_a.sentence: See, e. g., Van Coteghem v. Gray, 628 F.2d 488 (5th Cir. 1980) (plaintiff improperly dismissed for addressing public body on subject of civil rights for homosexuals); Hickman v. Valley Local School District Board of Education, 619 F.2d 606, 609 (6th Cir. 1980) (absent direct public criticism of superiors, personality conflict generated by protected union activities cannot justify discharge); Atcherson v. Siebenmann, 605 F.2d 1058, 1063 (8th Cir. 1979) (improper to silence employee who reveals misappropriation of public funds, despite resulting disharmony); cf. Serna v. Manzano, 616 F.2d 1165,1166 (10th Cir. 1980) (plaintiff’s secret tape recording of office conversations caused actual disruption); Janusaitis v. Middlebury Volunteer Fire Department, 607 F.2d 17 (2d Cir. 1979) (fireman properly dismissed for verbally attacking very persons with whom he functions in closest coordination).
citation_b.signal: cf.
citation_b.parenthetical: fireman properly dismissed for verbally attacking very persons with whom he functions in closest coordination
citation_b.sentence: See, e. g., Van Coteghem v. Gray, 628 F.2d 488 (5th Cir. 1980) (plaintiff improperly dismissed for addressing public body on subject of civil rights for homosexuals); Hickman v. Valley Local School District Board of Education, 619 F.2d 606, 609 (6th Cir. 1980) (absent direct public criticism of superiors, personality conflict generated by protected union activities cannot justify discharge); Atcherson v. Siebenmann, 605 F.2d 1058, 1063 (8th Cir. 1979) (improper to silence employee who reveals misappropriation of public funds, despite resulting disharmony); cf. Serna v. Manzano, 616 F.2d 1165,1166 (10th Cir. 1980) (plaintiff’s secret tape recording of office conversations caused actual disruption); Janusaitis v. Middlebury Volunteer Fire Department, 607 F.2d 17 (2d Cir. 1979) (fireman properly dismissed for verbally attacking very persons with whom he functions in closest coordination).