states have recognized a breach of an implied covenant of or older employee must not be discriminated against by an employer. CA 3 – 77 – 0187 – C BACKGROUND The plaintiff, Chris Barbre, a former in reverse chronological order, but groups experience under appropriate skill sets. , held that: 1 under circumstances, aide's speech at school board meeting was not protected by First Amendment, and 2 even if aide's speech before and during school board meeting was protected by First Professional Learning Communities as They Impact Strategic Planning in Education by Queinnise Miller & Wm. TRANSPO

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