of his public duties when speaking as a representative of the police union. We thus hold that a reasonable jury could find that El-lins’s speech, made as a representative and president of the police union, was made in his capacity as a private citizen. C. The district court also determined that Ellins failed to establish that he suffered an “adverse employment action.” Ellins argued that the fa City of Manhattan Beach, 881 F.2d 816, 819 (9th Cir.1989) (noting that a public employer cannot withhold an economic benefit “such as a higher salary” in retaliation for activities protected by the First Amendment). Even the denial of a minor financial benefit may form the basis of a First Amendment claim. See Elrod v. Burns, 427 U.S. 347, 359 n. 13, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976) (<HOLDING>). In addressing a First Amendment retaliation
holding that independent contractor claiming termination of contract because of lobbying and other political activities not protected by first amendment holding first amendment claim requires actual protected conduct holding that regulating the location of adult films does not violate the first amendment and citing as support the proposition that reasonable regulations of the time place and manner of protected speech where those regulations are necessary to further significant governmental interests are permitted by the first amendment holding that plaintiffs necessarily demonstrated irreparable harm because they showed a substantial likelihood that their first amendment rights had been infringed holding that first amendment rights are infringed both where the government fines a person a penny  and where it withholds the grant of a penny to punish or suppress protected activities