constitutionally protected speech;” and (3) “a causal relationship exists between [the plaintiffs] speech and the defendant’s retaliatory action.” See, e.g., Suarez Corp., Indus. v. McGraw, 202 F.3d 676, 686 (4th Cir. 2000). Examining these considerations, the Supreme Court repeatedly has struck down as violative of the First Amendment government actions that burden or penalize an individual or group for engaging in political speech. See, e.g., Rutan v. Republican Party of Ill., 497 U.S. 62, 65, 110 S.Ct. 2729, 111 L.Ed.2d 52 (1990) (concluding that First Amendment prohibits government employers from making “promotion, transfer, recall, and hiring decisions involving low-level public employees ... based on party affiliation and support”); Elrod, 427 U.S. at 373, 96 S.Ct. 2673 (<HOLDING>). Finally, partisan gerrymandering implicates
holding that independent contractor claiming denial of public contract because of political affiliation was not protected by first amendment 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 that the first amendment forbids government officials to discharge public employees for not being supporters of the political party in power holding that it was not clearly established that independent contractor claiming denial of public contract because of political affiliation was protected under first amendment