## Facts

- Marvin L. Pickering, a public high school teacher in an Illinois school district, wrote and published a letter to a local newspaper.
- The letter criticized the school board’s allocation of funds between educational and athletic programs and its communications with voters about proposed tax increases.
- The school board dismissed Pickering, concluding the letter contained false statements and was detrimental to the efficient operation and administration of the schools under state law.
- At the board hearing, no evidence was introduced showing the letter’s actual effect on school operations, Pickering’s classroom performance, or working relationships within the school.

## Issues

1. Whether a public school teacher may be dismissed for publishing a letter criticizing the school board on tax and spending issues consistent with the First and Fourteenth Amendments.
2. Whether alleged falsity in the teacher’s statements, without proof of knowing or reckless falsity, removes First Amendment protection.
3. How to balance a public employee’s speech rights as a citizen on matters of public concern against the government employer’s interest in efficient public service.

## Decision

- The Supreme Court reversed the state court and held the dismissal violated the First Amendment.
- The Court held that public employment cannot be conditioned on surrender of constitutional rights.
- Pickering’s letter addressed matters of public concern involving school funding and tax proposals.
- The record did not show that the letter impeded school operations, classroom performance, or necessary workplace relationships.
- Absent proof that any false statements were made knowingly or with reckless disregard for truth, the speech remained protected.

## Legal Principles

- Public employees retain First Amendment rights; government may not impose employment conditions that require waiver of constitutional speech protections.
- When a public employee speaks as a citizen on matters of public concern, courts must balance the employee’s interest in speaking against the employer’s interest in efficient and effective public services.
- The government employer must show actual or reasonably predictable disruption sufficient to outweigh the employee’s speech interest; generalized claims of harm are insufficient.
- False statements on public issues do not justify discipline unless made with knowledge of falsity or reckless disregard for truth.

## Conclusion

A public school teacher’s public commentary on school funding and tax policy is protected citizen speech, and dismissal is unconstitutional absent a showing that the speech materially disrupts school operations or that any false statements were made knowingly or recklessly.


Pickering v. Bd. of Educ. of Twp. High Sch. Dist. 205, 391 U.S. 563 (1968)