"Granting summary judgment based on such 'vague and conclusory' concerns, without more, runs the risk of constitutionalizing a heckler’s veto. Enough outsider complaints could prevent government employees from speaking on any controversial subject, even on their own personal time. And all without a showing of how it actually affected the government’s ability to deliver 'public services'—here, fighting fires and protecting public safety," Judge David R. Stras wrote.

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