SPEAK NO EVIL:
THE LEGAL
CONTOURS OF
BOARD MEMBER
SPEECH
Presented by:
Michael P. McKeon
November 21, 2015
© 2014 Pullman & Comley LLC 1
SPEAK NO EVIL
“Wise men speak because they have
something to say;
Fools because they have to say
something.”
Plato
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
 “[T]here shall always be free public
elementary and secondary schools in the
state.”
 Connecticut Constitution, Article Eighth, Section 1
 Sheff v. O’Neill, 238 Conn. 1 (1996).
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
 To implement that constitutional mandate, the
Connecticut General Assembly has invested
local and regional boards of education with
responsibility for implementing the educational
interests of the State.
 Conn. Gen. Stat. §10-220
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
 These interests include:

1.
The maintenance of “good public
elementary and secondary schools”;
 2.
The employment and dismissal of
teachers, subject to the requirements
of the Teacher Tenure Act, Conn.
Gen. Stat. §10-151;
 3.
The provision of student
transportation;
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
4.
The “care, maintenance and
6.
operation of the buildings, lands,
apparatus and other property used
for school buildings.”
The provision of “other educational
activities as in its judgment will best
serve the interests of the school
district”;
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
BUT WAIT A MINUTE . . .
JUST WHEN YOU WERE STARTING TO
SEE YOURSELF AS . . .
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
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THE LEGAL STATUS OF THE
BOARD OF EDUCATION
 1.
The board is a legal entity that is SEPARATE
AND APART from its individual board
members.
 2.
The statutory powers reside in the board of
education, NOT in individual board members.
 3.
Individual board members have NO legal
authority as individuals.
 4.
A school board member has NO more right to
bind the school district than does any other
member of the community.
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FREEDOM OF SPEECH
 The First Amendment to the United States
Constitution provides in relevant part:
 “Congress shall make no law . . . abridging
the freedom of speech.”
 Article First, Section Four of the Connecticut
Constitution also protects the right to free
speech.
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WHICH MEANS?
 The government may NOT -- without
substantial justification -- interfere with or
otherwise limit an individual’s, or even an
entity’s, attempt to express himself or herself,
orally, in writing, or in actions, particularly if the
government’s actions constitute an attempt to
regulate THE CONTENT of an individual’s
speech.
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FREE SPEECH AND PUBLIC
EMPLOYMENT
 “It is by now well established that public
employees do not check all of their First
Amendment rights at the door upon accepting
public employment.” Lewis v. Cowen, 165 F.3d
154, 158 (2nd Cir. 1999).
 There are, however, limitations . . .
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FREE SPEECH AND PUBLIC
EMPLOYMENT
 The United States Supreme Court has held:
 “[W]hen public employees make statements
PURSUANT TO THEIR OFFICIAL DUTIES, the
employees are NOT speaking as citizens for First
Amendment purposes, and the Constitution does
NOT insulate their communications from employer
discipline.” Garcetti v. Ceballos, 547 U.S. 410,
419-420 (2006)(emphasis added).
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FREE SPEECH AND PUBLIC
EMPLOYMENT
 Thus, federal courts have found that the following
communications were not entitled to First Amendment
protection:
1.
2.
3.
A teacher informing an administrator of an unsafe
learning environment;
A teacher writing to her principal that special
education students are not receiving appropriate
services;
A teacher challenging a building principal’s
requirement that all staff and students participate
in a Martin Luther King, Jr. Day assembly.
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FREE SPEECH AND PUBLIC
EMPLOYMENT
 FURTHER LIMITATIONS
 Even if a public employee can establish that he
spoke “as a citizen” rather than as an
employee, courts must still balance his right to
speak against the employer’s interest in
managing its workplace. Pickering v. Board of
Education, 391 U.S. 563, 568 (1968).
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FREE SPEECH AND PUBLIC
EMPLOYMENT
 What Constitutes Public Concern?
 “‘The FUNDAMENTAL QUESTION is whether the employee is seeking to
vindicate personal interests or to bring to light “a matter of political, social, or
other concern to the community.” Connick v. Myers, 461 U.S. 138, 147
(1983).
 Discussions “regarding current government policies and activities is perhaps
the paradigmatic matter of public concern.” Harman v. City of New York, 140
F.3d 111, 118 (2nd Cir. 1998).
 Matters of public concern also include “speech aimed at uncovering
wrongdoing or breaches of the public trust.” Wrobel v. County of Erie, 692
F.3d 22, 31 (2nd Cir. 2012)
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FREE SPEECH AND PUBLIC
EMPLOYMENT
 Thus . . .
 Employers “may still prevail if they demonstrate
that . . . plaintiff's speech was likely to disrupt
the government's activities, and the likely
disruption was sufficient to outweigh the First
Amendment value of plaintiff's speech.”
Waters v. Churchill, 511 U.S. 661, 668 (1994).
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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES?
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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES
THE COURTS HAVE SPOKEN, AND
THE ANSWER IS . . .
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MAYBE YES . . . AND MAYBE
NO



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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES?
 Cases decided prior to the Supreme Court’s decision in Garcetti
tended to view elected officials as having broad free speech
protections. For example:
 1.
 2.
 3.
“The role that elected officials play in our society makes it all the more
imperative that they be allowed freely to express themselves on
matters of current public importance.” Republican Party of Minn. v. White,
536 U.S. 765, 781–82 (2002).
“The exclusion of an officeholder from her office in retaliation for her political
views is a violation of the First Amendment.” Velez v. Levy, 401 F.3d 75,
101 (2nd Cir. 2005)
“[W]e have no difficulty finding that the act of voting on public issues by a
member of a public agency or board comes within the freedom of
speech guarantee of the first amendment. This is especially true when the
agency members are elected officials.” Miller v. Town of Hull, 878 F.2d
523, 532 (1st Cir. 1989).
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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES

Cases decided after Garcetti have been more
equivocal.
 1.
“Unlike an ordinary citizen, Plaintiff represents the Township
when he speaks at a public board meeting. Thus, his
constitutional rights are more analogous to the employee in
Garcetti than to a private citizen sitting in the audience.”
Shields v. Charter Twp. of Comstock, 617 F.Supp.2d 606, 61516 (W.D. Mich. 2009).
 2.
“Garcetti . . . makes clear that speech made pursuant to an
individual's official duties is not protected by the First
Amendment. The distinction between the public employee in
Garcetti and an elected official . . . is inconsequential.”
Hartman v. Register, No. 1:06-CV-33, 2007 WL 915193,
at
*6 (S.D. Ohio Mar. 26, 2007).
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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES
 But others . . .
 1.
 2.
“‘Voting by members of municipal boards, commissions, and
authorities comes within the heartland of First Amendment
doctrine, and the status of public officials’ votes as
constitutionally protected speech [is] established beyond
peradventrue of doubt.’” Blair v. Bethel Sch. Dist., 608 F3d
540, 545 (9th Cir.
2010), quoting Stella v. Kelley, 63
st
F.3d 71, 75 (1 Cir. 1995).
“[T]he plaintiff’s political speech regarding budgetary and fiscal
matters, zoning practices, human resource issues, and contract
awards was protected by the First Amendment.” Werkheiser v.
Pocono Township, 2013 WL 4041856 *9 (M.D. Pa. Aug. 8,
2013).
 IN SHORT . . .
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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES
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CONNECTICUT TO THE
RESCUE!
 On October 13, 2015, the Connecticut
Supreme Court held that Connecticut law
provides broader free speech rights than does
federal law. Thus, the mere fact that speech is
made pursuant to an individual’s job duties
does not automatically exclude it from statecreated protections.
 Trusz v. UBS Reality Investors, LLC, 319 Conn.
175 (2015)
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DO BOARD OF EDUCATION MEMBERS
HAVE GREATER FREE SPEECH RIGHTS
THAN THEIR EMPLOYEES
 TO SUMMARIZE
 One cannot state definitively whether or not
school board members’ First Amendment free
speech rights are subject to Garcetti’s
limitations, but they may have better luck under
Connecticut law.
 ONE RULE OF THUMB, THOUGH . . .
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IF THE JUDGE LOOKS LIKE THIS, THEN
YOUR SPEECH RIGHTS ARE PROBABLY
GOING TO BE LIMITED.
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NOW BEFORE YOU BREAK
OUT THE MEGAPHONE
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EVEN IF BOARD MEMBERS ENJOY
ROBUST FREE SPEECH RIGHTS, THERE
ARE EXCEPTIONS, INCLUDING:
 1.
Speech that incites imminent lawless action
 2.
“Fighting words” that are either injurious by themselves or
might trigger injurious behavior
 3.
Threats
 4.
Speech that appeals to the prurient interest, depicts or
describes sexual conduct in a patently offensive way, and
lacks serious literary, artistic, political, or scientific value.
 5.
Child pornography
 6.
Tortious misconduct, such as defamation or invasion of
privacy
 7.
Intentional infliction of emotional distress
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ALSO KEEP IN MIND
 Comments made by board members regarding employees or others can
be used to show bias in termination proceedings, such as under Conn.
Gen. Stat. §10-151, or in grievance proceedings under the relevant
collective bargaining agreement.
 Such comments can also result in legal consequences, specifically if the
comments are made public and are deemed to be malicious, willful or
wanton.
 Board members as well as the board of education have a duty to protect
the reputation of school district employees by avoiding public discussion
of employees except where the employee exercises his or her right to
have any such discussion in public session of a board meeting under the
Freedom of Information Act. Conn. Gen. Stat. §1-220.
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HOW ABOUT THE
SUPERINTENDENT?
 The powers and responsibilities that Section 10-220 confers on
school boards are largely directed at policy considerations such as
planning for the school district rather than the day-to-day
administration of the school system.
 In fact . . .
 Connecticut law provides that a local or regional school board
“shall provide for the supervision of the schools under its control by
a superintendent who shall serve as the chief executive officer of
the board.” Conn. Gen. Stat. §10-157
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HOW ABOUT THE
SUPERINTENDENT?
 Consequently . . .
 The superintendent “shall have executive authority over the school
system and the responsibility for its supervision.” Conn. Gen. Stat.
§10-157(a).
 In short, the school board develops and adopts policies, and the
school administration implements them.
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HOW ABOUT THE
SUPERINTENDENT?
 THE POINT?
 A board member clearly can exercise his or her right to raise
questions and to propose action, within school board rules and
regulations.
 But . . .
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HOW ABOUT THE
SUPERINTENDENT?
 A board member should NOT attempt to exercise authority he or
she does not possess, such as:
 1.
Going into a teacher's class to personally observe the
teacher’s performance;
 2.
attempting to single handedly negotiate a side letter to a
collective bargaining agreement without having been given
authority to do so;
 3.
leaking information to the press or others which he or she
received on a confidential basis as a member of the board of
education;
 4.
individually arbitrate parent or community complaints.
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IN CASE YOU FORGOT . . .
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IN CASE YOU FORGOT . . .
 1.
The board is a legal entity that is SEPARATE AND
APART from its individual board members.
 2.
The statutory powers reside in the board of
education, NOT in individual board members.
 3.
Individual board members have NO legal authority
as individuals.
 4.
A school board member has NO more right to bind
the school district than does any other member of
the community.
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OKAY, THEN, MR. KILLJOY,
WHAT DO YOU SUGGEST?
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HANDLING PARENT AND
COMMUNITY MEMBER
COMPLAINTS
 THE CORRECT APPROACH
 1.
Complaints should be referred to the superintendent of
schools, the building principal or the teacher involved, if
appropriate, for necessary action.
 2.
Given that communications are generally channeled through
the Board Chair, the Chair should be apprised of such
referrals.
 3.
To avoid confusion and help board members, the board of
education may wish to adopt a policy which deals with
complaints received by individual board members.
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HANDLING PARENT AND
COMMUNITY MEMBER
COMPLAINTS
 THE INCORRECT APPROACH
 Sending an e-mail such as the following to
fellow board members and administrators:
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HANDLING PARENT AND
COMMUNITY MEMBER
COMPLAINTS
 Dear all,
 We all know these 504 plans are a joke. I don't know
why the law teases parents with the 504s.
 There is always two sides to every story but, my
experience is that the quality of our guidance
counselors is, at best, mediocre. I've discussed this
with the Superintendent before -- these people are not
regularly evaluated or reviewed. They generally get
away with murder. This needs to change.
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OR AS I REACTED . . .
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SO WHAT’S THE BIG DEAL IF
YOU SAY THE WRONG THING?
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SO WHAT’S THE BIG DEAL . . .
L I A B I L I T Y !
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CONN. GEN. STAT. §10-235(b)
 “In the event such member, teacher or other employee
has a judgment entered against him for a malicious,
wanton or wilful act in a court of law, such board of
education or charter school shall be reimbursed by
such member, teacher or other employee for expenses
it incurred in providing such defense and shall not be
held liable to such member, teacher or other employee
for any financial loss or expense resulting from such
act.
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IN OTHER WORDS . . .
 Plaintiffs who believe that they have been aggrieved by a school
board, or by its members, can file suit against the school board as
an entity, and, in certain circumstances, against the board
members
themselves
IN
THEIR
INDIVIDUAL
CAPACITIES.
 If a board member is found to have acted with an intent to harm,
with deliberate indifference, or with reckless disregard, then the
board member is PERSONALLY LIABLE for any damages
entered against him or her as well as – under certain civil rights
enactments – the plaintiff’s attorneys’ fees.
Even worse,
INSURANCE
POLICIES
DO
INTENTIONAL MISCONDUCT.
NOT
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CONN. GEN. STAT. §10-235(b)
WHAT DOES THAT MEAN?
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BOARD MEMBER BEFORE
THE LAWSUIT
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BOARD MEMBER AFTER THE
LAWSUIT
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LIABILITY!
UNFORTUNATELY,
WHEN
AN
INDIVIDUAL
BOARD
MEMBER
INVITES LITIGATION, HE OR SHE
USUALLY TAKES ALONG THE
REST OF THE CREW
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LIABILITY!
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EXAMPLES
OF
BOARD
MEMBER
COMMUNICATIONS GONE TERRIBLY
WRONG
 Remember that e-mail? The one in which the board
member wrote:
 Dear all,
 We all know these 504 plans are a joke. I don't know why the law teases
parents with the 504s.
 There is always two sides to every story but, my experience is that the quality
of our guidance counselors is, at best, mediocre. I've discussed this with the
Superintendent before -- these people are not regularly evaluated or
reviewed. They generally get away with murder. This needs to change.
 Thanks for listening,
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HOW COULD THAT E-MAIL
HURT YOU? LET ME COUNT
THE WAYS
 1.
 2.
 3.
 4.
Susceptible to disclosure under the
Freedom of Information Act
Susceptible to disclosure under the Family
Educational Rights and Privacy Act
[“FERPA”]
Gives rise to claims of bias in future
teacher termination matters
Plaintiff’s Exhibit A in parent’s Section 504
lawsuit against school district.
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FURTHER EXAMPLES OF BOARD
COMMUNICATIONS GONE
TERRIBLY WRONG
 1.
In completing his evaluation of the Superintendent, a board
member likens
him to the boss of an organized crime family and
characterizes his administration as a criminal enterprise.
 2.
In response to parent complaints about school administrator,
board member agrees and opines that he too “never much
liked him.”
 3.
Following executive session pertaining to possible resignation of
teacher facing termination, board member shares information with
reporter, who promptly publishes article about the teacher and the
teacher’s alleged misconduct.
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EVEN MORE EXAMPLES OF
BOARD COMMUNICATIONS
GONE TERRIBLY WRONG
 4.
Board member e-mails to the rest of the board a
caricature of President Obama as an African
tribal chief with a caption that, to put it
euphemistically, is racially insensitive.
 5.
Following an executive session with the Board’s
attorney to discuss pending litigation brought by a
former administrator, Board member promptly
telephones the plaintiff, sharing the contents of the
session and the Board counsel’s proposed
strategy.
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HOW DOES A BOARD DEAL
WITH ERRANT MEMBERS?
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PREVENTIVE STEPS
 BOARD POLICIES
 The Board should ensure that it has policies in place that address
and delineate the procedures for the following:
 1.
Board conduct – civility, professionalism, ethics
 2.
How parent and community member complaints are
handled
 3.
Delineating the different responsibilities of the school board
and of the administration
 4.
Underscoring the fact that the school board and its members
are separate legal entities and that board members, as
individuals, do not have any legal powers or rights to dictate
board policy or district practice
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PREVENTIVE STEPS
 CONTENT-NEUTRAL RESTRICTIONS
 Content-neutral restrictions limit speech without
regard to its content or the substance of the
message conveyed. Consequently, courts will
typically afford more deference to contentneutral restrictions than to those that are
content-based.
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PREVENTIVE STEPS
 What’s the difference . . .?
 If a school board refuses to permit individuals to criticize board
members or district staff during the Public Comment section of a
board meeting, that would typically be held to be a violation of the
First Amendment, because it would be limiting speech based upon
the substance of the speaker’s comments.
 If a school board eliminates Public Comment altogether, or it
refuses to permit individuals to say anything – positive or
negative – about board members or district staff, then that would
be a content-neutral restriction.
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PREVENTIVE STEPS
 Similarly . . .
 If a school board limits board member speech to comments
that directly relate to items on the meeting agenda, that
would be considered content-neutral.
 Needless to say, such a policy cannot be applied in an
arbitrary manner, but must be applied uniformly.
 Additionally, if it were applied in an inflexible, draconian
measure, a court could find that despite its neutral basis, it is
unduly restricting speech.
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PREVENTIVE STEPS
 BOARD POLICIES
 Boards should also have in place policies
that provide for the possible censure or
reprimand of board members.
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CENSURE OR
REPRIMAND
 The Board may vote to censure or reprimand a member by a
two-thirds vote of the membership of the whole Board.
 Or
 The Board may vote to censure or reprimand a member by a
two-thirds vote of the membership of the whole Board. Such
vote may only take place after the board member in question
has been given an opportunity to respond to the evidence
supporting the censure or reprimand.
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CENSURE OR REPRIMAND
 Although the second version provides the
board member with an opportunity to be
heard, it can also have the unfortunate
consequence of providing the board
member with an opportunity to be heard.
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PREVENTIVE STEPS
 BOARD LEGAL COUNSEL PRESENTATION
 Following the election of new school board members,
the board should schedule a meeting with its legal
counsel to discuss the Roles and Responsibilities of
the Board.
 The purpose and focus of this meeting should be to
setting forth the different roles of the board and of the
administration, and the importance of discretion.
 Fire and brimstone regarding the threat of litigation can
also be helpful.
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PREVENTIVE STEPS

BOARD RETREATS

The board should schedule retreats on at least an
annual basis to review and reflect upon the school
board policies that address expectations of, and limits
on, individual board members.

The Board Chair may wish to consult with the school
board’s legal counsel regarding updates on laws that
affect school boards and their members. Similarly,
counsel may be able to
provide
hypotheticals
regarding common situations in which board
members may find themselves, discussing the
consequences of possible responses.
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RESPONSIVE STEPS
 NO RECALL PROVISION
 For better or for worse, Connecticut law does
not have a recall provision. That means that
once voted in, a public official remains in place
until the voters replace him or her, or he or she
voluntarily steps down.
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RESPONSIVE STEPS
 CENSURE OR REPRIMAND

As previously noted, school boards can vote to censure or
reprimand a board member who has violated board policies,
exposed the board to possible liability, or has otherwise
acted inappropriately.

The hope is that censure or reprimand will rehabilitate the
wayward board member or will, perhaps, serve as a means
of insulating the board and other board members from
subsequent complaints or lawsuits triggered by the board
member’s actions.
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RESPONSIVE STEPS
 CENSURE OR REPRIMAND
 Boards
MUST
EXERCISE
CARE
when
considering the censure or reprimand of a board
member. As noted, board members – like all
elected officials – have freedom of speech rights
under the First Amendment, and board members
who have been censured or reprimanded have
filed suit. Boards must, therefore, ensure that their
actions are based upon actual conduct, and that
that conduct reasonably warrants the consequence
of censure or reprimand.
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RESPONSIVE STEPS
 CENSURE OR REPRIMAND
Boards can, but are not required to, authorize
an investigation of the behavior in question,
which can be conducted by the board’s legal
counsel, by an independent counsel, or by
one-or-more board members appointed by the
remainder of the board. The drawback with
the latter approach is that it could trigger
claims that the investigation was biased.
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RESPONSIVE STEPS
 STRIPPING BOARD MEMBER OF ALL COMMITTEE ASSIGNMENTS


Just as a board member has no constitutional
right to an officer position on the school board,
there is no inherent right to serve on any
committee. Consequently, a school board
could authorize the Board Chair to decline
appointment of the board
member
to
any
committees.
Again, proceed ONLY AFTER THOROUGH
CONSIDERATION of this option.
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FORMING COMMITTEES COMPRISED
OF ALL BOARD MEMBERS BUT
PROBLEMATIC MEMBER
 Much of the work school boards conduct begin
and are extensively formed in committees.
What if a school board were to form a kind of
“super” committee, which consisted of all board
members except for a board member who was
engaging in inappropriate behavior? The work
of the board as a whole would then be to
simply vote on the super committee’s
recommendations.
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FORMING COMMITTEES COMPRISED
OF ALL BOARD MEMBERS BUT
PROBLEMATIC MEMBER
 As noted, Section 10-220 vests in SCHOOL
BOARDS the responsibility for implementing
the educational interests of the State. Thus,
implementing such committee might arguably
run afoul of Section 10-220, although it would
still be the entire school board that made the
ultimate decision on the matters that came
before it.
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FORMING COMMITTEES COMPRISED
OF ALL BOARD MEMBERS BUT
PROBLEMATIC MEMBER
 Perhaps of greater concern would be a
claim that the school board has essentially
disenfranchised this board member, and as
such, his or her First Amendment right to be
heard on matters of public concern had
been unconstitutionally restricted.
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FORMING COMMITTEES COMPRISED
OF ALL BOARD MEMBERS BUT
PROBLEMATIC MEMBER



In short, there is no guarantee that taking
such a dramatic measure would withstand
court scrutiny.
Furthermore, a similar result might be
reached
by stripping
the
board
member of committee assignments.
In any event, a school board should
absolutely FIRST OBTAIN A LEGAL
OPINION FROM THE BOARD’S LEGAL
COUNSEL before taking such a step.
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RESPONSIVE STEPS
 A rule of thumb . . .
 As should be true of any decision a board member
makes, the question that determines whether or
not the board takes a particular action is whether
there is AN OBJECTIVELY REASONABLE AND
RATIONAL JUSTIFICATION FOR THAT ACTION.
 Remember . . .
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RESPONSIVE STEPS
“Speak when you are angry - and you'll
make the best speech you'll ever
regret.”
Laurence J. Peter
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 If the inappropriate actions or communications
of a board member result in a lawsuit against
the school board and/or the other board
members, and if there is a reasonable legal
basis for doing so, the school board or the
other members can “Implead” the board
member who is at fault, thereby making him or
her what is termed a “Third-Party Defendant.”
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RESPONSIVE STEPS
 In other words . . .
The defendant school board or board members
would turn around and sue the board member
whose actions instigated the lawsuit, the theory
being that if the board or its members were
found liable, it was due to the fault of the errant
board member.
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RESPONSIVE STEPS
There are, of course, a number of considerations . . .
Under Conn. Gen. Stat. §10-235, the school
board would likely compelled to pay for the thirdparty-defendant board member’s legal fees, and,
if he or she were found negligent, Section 10235 would obligate the board to indemnify him or
her.
But . . .
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If the third-party-defendant board member were
found liable for having violated the law in an
intentional manner or in reckless disregard of the
law, then the that board member would be
obligated to reimburse the school board for the
legal fees expended on his or her behalf.
Furthermore, the board member would be
personally liable for any damages.
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CONCLUSION
 At times, it can seem as if the entire school
board is being held hostage by one
obstreperous board member. Connecticut law
has certainly not provided boards with many
options. Thus, sometimes one can only hope
that they take guidance from the following:
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CONCLUSION
First learn the meaning of what you say, and
then speak.
Epictetus
"Better to remain silent and be thought a fool
than to speak out and remove all doubt“
Mark Twain

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CONSULT WITH YOUR
LEGAL COUNSEL FIRST!!!
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CONSULT WITH YOUR
LEGAL COUNSEL FIRST!!!
MICHAEL P. MCKEON, ESQ.
PULLMAN & COMLEY, LLC
90 STATE HOUSE SQUARE
HARTFORD, CONNECTICUT 06103
TELEPHONE: (860) 424-4386
[email protected]
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These slides are intended for educational and informational purposes only. Readers are advised to seek
appropriate professional consultation before acting on any matters in this update. These slides may be
considered attorney advertising. Prior results do not guarantee a similar outcome.
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