Section 3617

Citation: Section 3617
Parent Document: Gonzalez v. Lee County Housing Authority, 161 F.3d 1290 (1998)
Jurisdiction: United States (federal)
Effective Date: 1998-12-02
Original Source: https://www.courtlistener.com/opinion/73387/gonzalez-v-lee-county-housing-authority/ ↗

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meritorious performance rather than political service.” Id. at 149, 103
S. Ct. at 1691.
     The Connick Court thus held that the public concern requirement was
satisfied even though Myers did not publicize the questionnaire and even
though no evidence indicated that the public, at the time Myers
circulated the questionnaire, knew about the District Attorney’s unlawful
practice of pressuring his employees to work on political campaigns. We
reject Moran’s contention that Peterson v. Atlanta Hous. Auth., 998 F.2d
904 (11th Cir. 1993), indicates a contrary rule. Although Peterson’s
inter-office speech did concern an issue that had received media
scrutiny, see id. at 916, the court specifically noted that public
awareness of the problem was not necessary to satisfy the public concern
requirement, see id. at 917 n.25; see also Morgan v. Ford, 6 F.3d 750,
754 n.5 (11th Cir. 1993) (“[A] court cannot determine that an utterance
is not a matter of public concern solely because the employee does not
air the concerns to the public.”); Deremo v. Watkins, 939 F.2d 908, 911
n.3 (11th Cir. 1991) (stating that an employee’s effort to communicate
her concerns to the public is a relevant, but not dispositive, element
in the public concern analysis).

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