Coloring Outside the Lines: Garcetti v. Ceballos in the Federal Appellate Courts, 262 EDUC. L. R. 357 (2011) (with Scott Bauries)

When the Supreme Court recognizes an exemption from First Amendment protections, the lower courts have an important responsibility to faithfully apply the exemption, a duty which includes the responsibility to read such a rights-limiting rule strictly.' When a speech limitation applies to the speech of public educators, lower courts must exercise particular care to apply the limitation on its terms and to avoid expanding it beyond its initial boundaries.