After the U.S. Supreme Court’s decision in Garcetti several years ago, there was a lot of chatter about whether public employees still had substantive First Amendment free speech rights.

And for a short while, the trend did seem to indicate that speech that related to an employee’s “official job duties” was to be construed

Earlier this year, the Second Circuit came out with an important, wide-ranging decision that clarified the protections that public employees have under the First Amendment. Specifically, any speech that is "pursuant to" an employee’s duties is not protected.

In a summary order last week arising out of Connecticut, the Second Circuit reinforced that fact. In

In a case with wide-ranging implications for First Amendment cases in Connecticut (and New York), the Second Circuit today held that a school teacher’s union grievances were not protected speech.

The case, Weintraub v. Board of Education of New York (download here) covers a lot of ground, but it chimes in on an issue the