each held that evidence of actual disruption is not required. See, e.g., Munroe v. Cent. Bucks Sch. Dist., 805 F.3d 454, 472 (3d Cir. 2015) (“The government need not show the existence of actual disruption if it establishes that disruption is likely to occur because of the speech.”); Lewis v. Cohen, 165 F.3d 154,163 (2d Cir. 1999) (“The State need show only a ‘likely interference’ with its operations, and ‘not an actual disruption.’ ” (citations omitted)); Brewster v. Bd. of Educ. of Lynwood Unified Sch. Dist., 149 F.3d 971, 979 (9th Cir. 1998) (“[P]ublic employers need not allege that an employee’s expression actually disrupted the workplace; ‘reasonable predictions of disruption’ are sufficient.” (citation omitted)); Shahar v. Bowers, 114 F.3d 1097, 1108 (11th Cir. 1997) (en banc) (<HOLDING>)-, Wallace v. Benware, 67 F.3d 655, 661 n.8
holding that under colorado law tjortious interference with a prospective business relation requires a showing of intentional and improper interference preventing formation of a contract holding that a particularized showing of interference with the provision of public services is not required under pickering holding that the difference between interference with contract and prospective relations is that second tort requires showing of malice recognizing that public utilities affect the public interest in that they render essential public services to a large number of the general public holding there were no grounds for challenging in a termination proceeding the alleged failure to comply with the ada in the provision of services because services are not required by the termination statute