a letter to a local newspaper or discussing politics with a co-worker, noting that these activities are “the kind of activity engaged in by citizens who do not work for the government.” Id. at 423-24, 126 S.Ct. 1951 (citations omitted). In assessing this key consideration, the Supreme Court emphasized that “[f|ormal job descriptions often bear little resemblance to the duties an employee actually is expected to perform, and the listing of a given task in an employee’s written job description is neither necessary nor sufficient to demonstrate that conducting the task is within the scope of the employee’s professional duties for First Amendment purposes.” Id. at 424-25, 126 S.Ct. 1951; see also Weintraub v. Bd. of Educ. of City Sch. Dist. of City of N.Y., 593 F.3d 196, 203 (2d Cir.2010) (<HOLDING>). Courts considering this question in the wake
holding that under the first amendment speech can be pursuant to a public employees official job duties even though it is not required by or included in the employees job description or in response to a request by the employer holding that a transfer of job duties can constitute an adverse employment action holding that a change in job duties was not an adverse employment action where the new job duties did not constitute qualitatively inferior work requiring any less skill or knowledge holding that garcetti barred claims involving speech not necessarily required by the plaintiffs job duties but nevertheless  related to his job duties holding that when public employees make statements pursuant to their official duties the employees are not speaking as citizens for first amendment purposes and the constitution does not insulate their communications from employer discipline