This is not a prison case but has implications for the scope of First Amendment protections for prisoner speech. The case involves a Chicago firefighter fired for making a series of racist posts on Facebook. The issue before the 7th Circuit was the limits of First Amendment protections for the speech of government employees.

Of interest to prisoner rights litigators is the lengthy discussion (pp. 8—18 of the slip opinion) of what qualifies as speech regarding matters of public interest (the first step in determining if speech is protected by the 1st Amendment. In the prison context this often comes up regarding grievances filed by prisoners. People are regularly disciplined for “Threats and intimidation” based on grievances, and the issue becomes whether the grievance relates to purely private concerns (in which case it is not covered by the 1st Amendment at all) of matters of public interest (in which case the discipline gets analyzed using the four factors identified by the Court in Turner).