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the realm of education, however, stands in stark contradiction to the ruling in Pickering v. Board of Education.
In Garcetti v. Ceballos' 5-4 ruling, Justice Kennedy's majority opinion in essence unraveled that which Justice Marshall had delivered nearly forty years earlier. The Court's opinion noted, "when 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, 2006). In the context of academic freedom, this ruling affords the daring teacher nationwide less recourse than what had previously existed in a piecemeal sense from one United States Circuit Court district to another.

Questions of academic freedom, either pursued by or brought upon the daring teacher, are not limited simply to cases of the clear and pronounced challenges to curriculum as seen in Kirkland v. Northside, however. In some instances, teachers have brought questions of academic freedom to the courts simply through performing their jobs, as they believed, to the best of their abilities.
Such was the case in Sterzing v. Fort Bend Independent School District. A high school civics teacher, Henry Sterzing was charged with teaching race relations as well as other current events to his seniors in a conservative Texas community in the late 1960's. After a series of complaints largely regarding Sterzing's distribution of anti-war material throughout his service to the school, Sterzing's approach to a board-approved unit on race relations finally fostered action from the administration. Though Sterzing used board-approved materials, the nature of the class created questions to which parents found Sterzing's responses objectionable. Parents complained to the school's principal in early 1968 after Sterzing had given a "truthful response to a student's classroom question that he was not opposed to interracial marriages" (Sterzing v. Fort Bend Independent School District, 1972).
Initially, the administration's response was to inform Sterzing through channels that he was to "confine his teaching to the text" and "not discuss controversial issues" (Sterzing v. Fort Bend Independent School District, 1972). Sterzing and his department chairperson concluded it would be extraordinarily difficult to teach civics to high school seniors without discussing the issues in the text, and agreed that he should proceed with

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