le work environment. In the Ninth Circuit, "speech related to scholarship or teaching" is governed by the test articulated by the Supreme Court in Pickering v. Board of Education, 391 U.S. 563 (1968), 5 EFTA00794004 rather than the more recent test in Garcetti v. Ceballos, 547 U.S. 410 (2006). See Demers v. Austin, 746 F.