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 content it allowed within university classrooms. Thus, unlike in Bishop, the context of these cases weighs against the State of Florida’s interest in prohibiting university employees from expressing certain viewpoints during training or instruction.

Which leads this Court to the second, somewhat-overlapping Bishop factor—namely, the State of Florida’s “position as a public employer which may reasonably restrict the speech rights of employees more readily than … those of other persons.” Bishop, 926 F.2d at 1074. Without a doubt, the State of Florida is accorded more flexibility to limit public employee speech as opposed to private individuals’ speech. Id. at 1072 (discussing Pickering v. Bd. of Educ., 391 U.S. 563 (1968)). Nonetheless, such limitations must be both reasonable and supported by evidence of a sufficiently weighty interest to overcome the employee’s right to speak.

For example, in Bishop, the Eleventh Circuit credited the University’s interest in controlling its curriculum and avoiding an establishment violation, which motivated the University to order Dr. Bishop to cease injecting his religious beliefs into his class discussions on exercise physiology. Bishop, 926 F.2d at 1076 (“[T]he University’s interests in the classroom conduct of its professors are sufficient, in the balance we have suggested, to warrant the reasonable restrictions it has imposed on Dr. Bishop.”). Likewise, the Eleventh Circuit held that the University of Alabama’s