What is the test for determining whether a statement by an employee can be characterized as speech involving a matter of public concern?

MultiRegion, United States of America

The following excerpt is from Chateaubriand v. Gaspard, 97 F.3d 1218 (9th Cir. 1996):

Courts look to "the content, form, and context of a given statement" to resolve this issue. Id. at 147-48, 103 S.Ct. at 1690. "Employee expression that can be fairly considered as relating to a matter of political, social, or other concern to the community may be characterized as speech involving a matter of public concern." Voigt v. Savell, 70 F.3d 1552, 1559 (9th Cir.1995) (citing Connick, 461 U.S. at 146, 103 S.Ct. at 1689-90), cert. denied, --- U.S. ----, 116 S.Ct. 1826, 134 L.Ed.2d 931 (1996).

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