“there would be problems with Ms. Adlard because of the previous lawsuit” if Perry were promoted. Miller also admitted in her deposition that she probably told Thomas that Adlard would have a question if Perry were promoted. This evidence indicates that Miller’s motivations- were retaliatory in nature: Miller was unwilling to promote Perry due to “problems” created by Perry’s past lawsuit. Moreover, Miller’s treatment of Perry need not have been actually unlawful for Thomas’ opposition to be protected expression. See Ceballos, 361 F.3d at 1179 (concluding that an assistant district attorney engaged in protected speech when he alleged criminal wrongdoing by an officer even though those allegations proved to be erroneous); Johnson v. Multnomah County, Or., 48 F.3d 420, 424 (9th Cir.1995) (<HOLDING>). [4] Although Thomas did not explicitly tell
holding that statements made only to supervisor and chief by police officer were matters of public concern holding that when a person reports cases of possible patient abuse that speech is a matter of public concern holding that an employees accusations of mismanagement and possible criminal conduct against her immediate supervisor constituted speech of public concern even though they were recklessly false holding public employees conduct and expression in internal investigation of employees at county prosecutors office to expose potential wrongdoing constituted matter of public concern holding commonlaw presumption that defamatory speech is false cannot stand when plaintiff sues media defendant for speech of public concern