Dixon v. University of Toledo

Petition for certiorari denied on October 7, 2013

Issue: (1) Whether the policymaker exception analysis from Elrod v. Burns and Branti v. Finkel should apply to employee speech cases that do not involve political patronage; and (2) whether a presumption in favor of protecting the free speech interests of a government employee should apply in a case not involving political patronage and where the employee is speaking as a private citizen on a matter of public concern and the speech does not directly criticize her employer or any identified policy of her employer.