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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Greg Moore v. Sean Garnand, 83 F.4th 743 (2023)

Citation
Greg Moore v. Sean Garnand, 83 F.4th 743 (2023)
Parent Document
Greg Moore v. Sean Garnand, 83 F.4th 743 (2023)
Effective Date
2023-09-29

Other Sections in This Document (42)

Full Text

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investigation could violate the First Amendment. Even assuming
without deciding that Coszalter suggested as such, we never held that a
retaliatory investigation alone could violate the First Amendment, as our
holding rested on much more than just a retaliatory investigation. See
id. at 976–77 (listing numerous retaliatory acts and concluding that
“[w]hen taken together, it is clear that these acts amounted to a severe
and sustained campaign of employer retaliation that was ‘reasonably
likely to deter’ plaintiffs from engaging in speech protected under the
First Amendment” (emphasis added)).
20                          MOORE V. GARNAND