At issue in Connick v. Myers (1983) was whether a former assistant district attorney (ADA) who was dismissed for conducting a survey about morale in the district attorney's office was speaking as a private citizen on a matter of public concern. The Supreme Court found that the survey's content did not involve matters of public concern but rather employee grievances potentially disruptive to the district attorney's office and thus was not protected under the First Amendment.

In light of Connick and related cases, it may be more difficult for public employees such as teachers to prove that they are speaking as private citizens on matters of public concern when they voice complaints about internal school operations. Among the questions that need to be resolved are where ...