The U.S. Court of Appeals for the Eighth Circuit recently affirmed the U.S. District Court for the Western District of Missouri's denial of summary judgment based on qualified immunity to two individual defendants who had been sued for First Amendment retaliation under Section 1983. The decision hinged on whether a genuine issue of material fact existed as to whether the plaintiffs—two former police officers—spoke as citizens on matters of public concern when they complained in writing to the mayor about the police chief.