assertions to the contrary. It forbids, at the risk of expulsion from the forum, speech which contains any “charges or complaints against any employee of the District, regardless of whether or not the employee is identified by name or by any reference which tends to identify the employee.” It is difficult to imagine a more content-based prohibition on speech than this policy, which allows expression of two points of view (laudatory and neutral) while prohibiting a different point of view (negatively critical) on a particular subject matter (District employees’ conduct or performance). In fact, policies which attempt to suppress or burden only critical speech are regularly held to be content-based. See, e.g., Westbrook v. Teton Cnty. Sch. Dist. No. 1, 918 F.Supp. 1475, 1494 (D.Wyo.l996)(<HOLDING>); Rubin v. City of Santa Monica, 823 F.Supp.
holding that petitioners status as school board members does not permit them to step into the shoes of the school board and invoke its right to appeal holding that school officials may not limit the first amendment rights of students and teachers to freedom of speech and expression holding that a school districts policy which limited and restricted teachers speech criticizing other staff members administrators or school board members by restricting the audience to which such criticisms could  be directed was contentbased because it distinguished between favored and disfavored speech on the basis of the views expressed holding that a teacher could not be dismissed for criticizing school boards budget management even though the criticism included false allegations against board members because the speech addressed a matter of public concern and the speech did not prevent the school districts efficient functioning holding that a collective bargaining agreement between school board and teachers union established a teachers legitimate claim of entitlement to their positions at elementary school