acknowledge that Garcetti addresses mostly free speech claims, as opposed to political affiliation or freedom of association claims: But Garcetti’s concerns about the "delicate balancing" of public-employee rights and government flexibility, as well as its anxiety about “judicial intervention in the conduct of governmental operations,” are not applicable only in the free speech context. 547 U.S. at 423, 126 S.Ct. 1951. Those concerns, for example, also underlie the so-called policymaker exception: the principle that political affiliation, for certain public employees, is an "appropriate requirement for continued tenure.” O’Connell, 724 F.3d at 126 (quoting Rosenberg v. City of Everett, 328 F.3d 12, 18 (1st Cir, 2003)); see also Maymí v. P.R, Ports Auth., 515 F.3d 20, 27 (1st Cir. 2008) (<HOLDING>). 6 . Speaker Eves cites several other
holding that independent contractor claiming removal from city towing rotation list because of political affiliation was not protected by first amendment recognizing that both an officials political affiliation and her substantive views on agency matters are permissible justifications for firing or demotion when she occupies a policymaking role citing flynn v city of boston 140 f3d 42 47 1st cir 1998 holding that first amendment prohibits government officials from discharging or threatening to discharge lowerlevel public employees based on their political affiliation holding that independent contractor claiming termination of contract because of political affiliation not protected by first amendment recognizing a life tenants power to lease not only her present interest in the land she occupies but also a future interest she owns in the same land