In Nolan v. Terry, the plaintiff were two former guards at the Botetourt Correctional Center, who brought suit claiming that they were retaliated against by the warden and his second-in-command for their protected speech on matters of public concern.
The Court granted the defendants' motion for summary judgment, concluding that the alleged "speech" was not protected, as the subject matter was job-related grievances, rather than matters of public concern, under the Supreme Court's decisions in Garcetti v. Ceballos and Connick v. Myers.
Which brings to mind another question, why are these leading First Amendment cases lawsuits against big city prosecutors like Connick in New Orleans and Garcetti in Los Angeles?
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