from the line of Supreme Court cases upholding the limited power of governments to restrict their employees’ political speech in order to promote the efficiency and integrity of government services. See, e.g., Pickering v. Bd. of Educ. of Twp. High Sch. Dist. 205, 391 U.S. 563, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968) (balancing interests of school district against teacher’s First Amendment rights); Letter Carriers, 413 U.S. 548, 93 S.Ct. 2880, 37 L.Ed.2d 796 (upholding Hatch Act restrictions on political activities of federal employees); Connick v. Myers, 461 U.S. 138, 103 S.Ct. 1684, 75 L.Ed.2d 708 (1983) (balancing the government’s interest in running an effective workplace against employees’ free speech rights); Garcetti v. Ceballos, 547 U.S. 410, 126 S.Ct. 1951, 164 L.Ed.2d 689 (2006) (<HOLDING>). In adopting the Pickering line of cases,
holding that the government can restrict a public officials speech if it is necessary to the effective delivery of public services recognizing that public utilities affect the public interest in that they render essential public services to a large number of the general public recognizing the need to balance the states interest in fulfilling its responsibilities to the public the extent to which the speech in question involves a matter of public concern and the manner time place and context of the speech holding that alleged misconduct by public officials particularly by law enforcement officials is matter of public concern recognizing criticisms of public officials is at core of speech protected by first amendment