“…In addressing this topic, it is important to define “public employee.” According to Massaro (1987), public employees include “public elementary and high school personnel, public university personnel, firefighters, police officers, postal workers, public welfare workers, the judiciary, military personnel, executive appointees, and a host of other workers employed by local, state, or federal governments” (p. 6). Brock (2001) notes that the public sector employees account for about 20.2 million people which makes up about 14.5 of the labor force in the United States. Although the free speech rights of private employees are limited with some conditions, the U.S. Supreme Court has repeatedly asserted that “it has been settled that a State cannot condition public employment on a basis that infringes the employee’s constitutionally protected interest in freedom of expression” (see Branti v. Finkel, 445 U.S. 507, 515-516, 1980; Connick v. Myers, 461 U.S. 138, 142, 1983; Garcetti v. Ceballos, 547 U.S. 410, 413, 2006; Keyishian v. Board of Regents, 385 U.S. 589, 605-606, 1967; Perry v. Sindermann, 408 U.S. 593, 597, 1972; Pickering v. Board of Education, 391 U.S. 563, 1968).…”