The 9.9 Particular Rights-First Amendment-Public Employees-Speech refers to the right of public employees to speak freely on matters of public concern without fear of reprisal from their employer. This protects public employees from being disciplined, fired, or otherwise retaliated against for speaking out on matters of public concern. This protection applies to all public employees, including teachers, police officers, firefighters, and other government employees. There are two types of 9.9 Particular Rights-First Amendment-Public Employees-Speech: pure speech and expressive conduct. Pure speech involves the spoken or written words, while expressive conduct involves physical action that conveys a message. Both types of speech are protected under the First Amendment.