What is the test for First Amendment retaliation in the context of Page 3?

A plaintiff claiming First Amendment retaliation must make a prima facie showing of (1) constitutionally protected speech, (2) an adverse action, and (3) a causal connection between that adverse action and the protected speech. Matthews v. City of New York, 779 F.3d 167, 172 (2d Cir. 2015). The doctrine in this area balances two important interests: "Government employers, like

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private employers, need a significant degree of control over their employees' words and actions," and yet, "public employees do not surrender all their First Amendment rights by reason of their employment." Garcetti v. Ceballos, 547 U.S. 410, 417-18 (2006).