Luz Gonzalez v. Lee County Housing Authority, 161 F.3d 1290 (1998)

Citation: Luz Gonzalez v. Lee County Housing Authority, 161 F.3d 1290 (1998)
Parent Document: Luz 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/759590/luz-gonzalez-v-lee-county-housin... ↗

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In reviewing Gonzalez's letter of September 28, the threshold question is whether the letter can "be fairly characterized as constituting speech on a matter of public concern...." Connick, 461 U.S. at 146, 103 S.Ct. at 1690. According to Moran, the letter does not satisfy the public concern requirement because Gonzalez did not distribute her letter publicly and because Gonzalez has not shown that her letter addressed specific matters that already had drawn significant public attention. In Connick, however, the Supreme Court held that the public concern requirement was satisfied where a government employee spoke about an important matter of public interest, even though the employee spoke only within the workplace and even though the specific matter addressed had not drawn significant public attention prior to her speech. See id. at 149, 103 S.Ct. at 1691.22

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