Williams v. Dallas Independent School District

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• recognizing that Garcetti “did not explicate what it means to speak ‘pursuant to’ one’s ‘official duties’ ”
• concluding that speech was not protected when the employee’s knowledge was derived from his position, he spoke to other employees, and the speech concerned the subject matter of his employment
• concluding that the plaintiff acted as an employee despite the fact that he was not required to write a memoranda complaining about funding
• holding that a school athletic director’s memoranda expressing concern regarding the handling of school athletic funds were not protected speech because they were “part-and-parcel of his concerns about the program he ran”
• stating that “[u]nder Garcetti, we must shift our focus from the content of the speech to the role the speaker occupied when he said it” to determine whether the speaker was “acting in her role as ‘citizen’ ”
• holding employee’s memo to external agency was within his job duties because it was “focus[ed] on his daily operations,” and he needed the information “so that he could properly execute his duties”

Source: CourtListener parenthetical corpus (CC0).