article. At oral argument, Wade specifically conceded to this Court that he had the burden to prove falsity. Moreover, as we have earlier noted, the plaintiff bears the burden to prove falsity in a defamation suit against a media defendant when the suit involves an issue of public concern. See Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767, 775-76, 106 S.Ct. 1558, 1563, 89 L.Ed.2d 783 (1986); see also Connick v. Myers, 461 U.S. 138, 145, 148, 103 S.Ct. 1684, 1689, 1690-91, 75 L.Ed.2d 708 (1983) (describing speech seeking to "bring to light actual or potential wrongdoing or breach of public trust” on the part of a government official as speech on matter of public concern that is protected by the First Amendment); Brawner v. City of Richardson, 855 F.2d 187, 191-92 (5th Cir.1988) (<HOLDING>). 16 . We do not address whether, and, if so,
holding that the government can restrict a public officials speech if it is necessary to the effective delivery of public services holding that the absence of a motivating desire to address a matter of public concern was not dispositive as to whether the speech addressed a matter of public concern holding that alleged misconduct by public officials particularly by law enforcement officials is matter of public concern holding allegations of wrongdoing by public officials are on the highest order of first amendment concern holding that an officers report of misconduct by fellow officer is a matter of public concern