A review of 16 Federal Court of Appeals cases indicates the impact of the "Connick v. Myers" case on the nature of freedom of speech in public organizations. The case involved the firing of an assistant district attorney for circulating a job satisfaction survey after she was transferred to a less desirable section of the courts. Since the 1983 Supreme Court decision, the organizational communication of public employees has been constitutionally protected only if the communication pertains to a matter of public concern and outweighs any potential harm to organizational efficiency. The courts still lack a consensus on the matter of how communication within organizations affects and is affected by the outside environment. The factual situations of each case provide insights into how some managers try to control communication within their organizations. The courts continue to argue over what constitutes a "matter of public concern" and to weigh the interest of free communication against that of organizational efficiency. The following tentative conclusions about the effects of the Connick case on the issue of public employee freedom of speech can be drawn: (1) the Connick Test has encouraged judicial restraint, (2) considerable confusion exists regarding the timing of comments, and (3) the problem of actual or potential disruption clouds the protection of employee free speech. (JD)