10.2190/L3KQ-MLJK-UMTU-Y1JD L3KQMLJKUMTUY1JD 1 Public Employee Protected Speech in the Wake of <i>Waters v. Churchill</i> 1 9 20020509 20020509 20020509 20020509 L3KQMLJKUMTUY1JD.pdf http://baywood.metapress.com/link.asp?target=contribution&id=L3KQMLJKUMTUY1JD 1 Bernadette Marczely Ed.D., J.D. Cleveland State University, Ohio The Supreme Court's recent decision in <i>Waters v. Churchill</i> will have a significant impact on protected speech in public employment. It will also have a significant effect on the procedures public employers use to investigate instances of employee expression leading to termination. In the final analysis, however, this plurality decision appears to pose more questions than answers and could give rise to a new kind of public sector employment litigation.