Pickering approach:  This approach is somewhere in between the two above approaches.  The First Am. prevents certain government  restrictions, while it allows others.  “The problem in any case is to arrive at a balance between the interests of the [government employee], as a citizen, in commenting upon matters of public concern and the interest of the State, as an employer, in promoting the efficiency of the public services it performs through its employees.”
This is the famous Pickering balancing test.