b)    Connick v. Meyers:  if the speech is on a matter of public concern ? court must subjectively balance the speech rights of the employee v. the government’s (employer’s) rights in promoting job efficiency.  [If not speech on matter of public concern => gov’t can pretty much fire him.]
i)    Public concern:  Rankin  when employee said about Reagan’s shooting “next time I hope they get him” it was political commentary and thus speech on a matter of public concern