California, United States of America
The following excerpt is from Shimoyama v. Board of Education, 120 Cal.App.3d 517, 174 Cal.Rptr. 748 (Cal. App. 1981):
Speaking of an analogous problem in a case involving the disciplining of a police officer for publishing a letter critical of his immediate superior, the court in Unruh v. City Counsel (1978) 78 Cal.App.3d 18, 24, 143 Cal.Rptr. 870, said:
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