In Rankin v. McPherson (1987, clerk was fired under a Texas statute by her Constable-boss for wishing that President Regan was killed), the US Supreme Court held that the:

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The US Supreme Court held that the public employee had a constitutional right to free speech, even hate speech, with some limits. The court recognized that there may be limitations on the speech of public employees when it involves matters of public concern and disrupts the efficiency of the workplace. However, in this case, the court found that the clerk's statement was not disruptive to the workplace and therefore protected speech. The court stated that "the First Amendment protects a public employee's right, in certain circumstances, to speak as a citizen addressing matters of public concern."

In Rankin V