The discussion of the Garcetti case is frankly misleading as the Supreme Court specifically refused to address faculty speech. The reference to Sheldon v. Dillion is also misleading. The court in Sheldon actually ruled for the faculty member and not the institution. More relevant is the Ninth Circuit’s en banc ruling in Demers v. Austin (2014). The Ninth Circuit wrote, “We hold that Garcetti does not apply to “speech related to scholarship or teaching.’”