speech was made by an employee of the government, and the government’s retaliation for that speech took the form of an adverse-employment action, such as termination of employment, decreased compensation, or refusal to consider for hiring or re-hiring. Id. Often in First Amendment retaliation cases, the government is claimed to have retaliated against the plaintiff for her own speech; but the First Amendment may also be violated where the speech that invoked the government’s retaliatory response was not made by the plaintiff herself, but rather by a person in a close relationship with the plaintiff, and the government retaliated against the plaintiff for her perceived association with the other person and that person’s speech. See, e.g., Adler v. Pataki, 185 F.3d 35, 45 (2d Cir.1999) (<HOLDING>); Talley v. Brentwood Union Free Sch. Dist.,
holding that first amendment principles preclude recovery under state law for damages caused by speech or other protected conduct holding that retaliatory discharge is a clearly established first amendment violation recognizing criticisms of public officials is at core of speech protected by first amendment recognizing the tort of retaliatory discharge holding that retaliatory discharge based solely on protected speech by ones spouse is actionable under the first amendment