What is the current state of the law on "particularized" freedom of speech?

MultiRegion, United States of America

The following excerpt is from Skaarup v. City of North Las Vegas, 320 F.3d 1040 (9th Cir. 2003):

The balancing that must be undertaken to find constitutional protection for the speech is "particularized" and depends "upon the nature of the employee's expression." Connick v. Myers, 461 U.S. 138, 150, 103 S.Ct. 1684, 75 L.Ed.2d 708 (1983). "When close working relationships are essential to fulfilling public responsibilities, a wide degree of deference to the employer's judgment is appropriate." Id. at 152-53, 103 S.Ct. 1684.

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