Dixon v. University of Toledo

(1) Whether the policymaker exception analysis from Elrod v. Burns and Branti v. Finkel should apply to employee speech cases that do not involve political patronage; and (2) whether a presumption in favor of protecting the free speech interests of a government employee should apply in a case not involving political patronage and where the employee is speaking as a private citizen on a matter of public concern and the speech does not directly criticize her employer or any identified policy of her employer.