This is confirmed by Garcetti 2006: > that because his statements were made pursuant to his position as a public employee, rather than as a private citizen, hi

This is confirmed by Garcetti 2006: > that because his statements were made pursuant to his position as a public employee, rather than as a private citizen, his speech had no First Amendment protection. https://en.wikipedia.org/wiki/Garcetti_v._Ceballos https://en.wikipedia.org/wiki/Garcetti_v._Ceballos