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    NUNEZ v CITY OF LOS ANGELES, 9755139

    U.S. 9th Circuit Court of Appeals

    NUNEZ v CITY OF LOS ANGELES
    9755139

    DAVID NUNEZ, ALEX GOMEZ, and
    CLYDE ANTHONY VLASKAMP,
    Plaintiffs-Appellants,
    No. 97-55139
    v.
    D.C. No.
    CITY OF LOS ANGELES, the LOS
    CV-95-2446-DT
    ANGELES POLICE DEPARTMENT,
    CHIEF WILLIE WILLIAMS, CAPTAIN                        OPINION
    JAMES TATREAU, CAPTAIN LEE
    CARTER, SERGEANT GARY GRUBBS,
    Defendants-Appellees.
    
    
    Appeal from the United States District Court
    for the Central District of California
    Dickran Tevrizian, District Judge, presiding
    
    Argued and Submitted
    April 9, 1998--Pasadena, California
    
    Filed June 5, 1998
    
    Before: Jerome Farris, Diarmuid F. O'Scannlain, and
    Ferdinand F. Fernandez, Circuit Judges.
    
    Opinion by Judge O'Scannlain;
    Concurrence by Judge Farris
    
    _________________________________________________________________
    
    COUNSEL
    
    Russell J. Cole, Law Offices of Paul R. DePasquale, Los
    Angeles, California, for the appellants.
    
    Leslie E. Brown, Assistant City Attorney, Los Angeles, Cali-
    fornia, for the appellees.
    
    _________________________________________________________________
    OPINION
    
    O'SCANNLAIN, Circuit Judge:
    
    We must decide whether a Los Angeles police officer has
    a constitutionally protected property or liberty interest in pro-
    motion to higher rank.
    
    I
    
    The Los Angeles Police Department ("LAPD") administers
    an examination for police officers who wish to be promoted
    to the position of lieutenant. The test contains written and oral
    components. If a candidate scores high enough -- 65% on the
    written portion and 70% overall -- his or her name is added
    to a list of qualified prospects. The list is organized by bands,
    or groups, of scores; the Chief of Police must exhaust the can-
    didates within a given band before selecting anyone from a
    lower band. As positions become available, candidates are
    chosen until such time as the list expires.
    
    Not just any officer can take the examination. According to
    official policy, a candidate must have, among other creden-
    tials, at least one year of supervisory experience. It is undis-
    puted that officers David Nunez, Alex Gomez, and Clyde
    Anthony Vlaskamp (collectively, the "police officers") all ful-
    filled this requirement and each took the examination at least
    once. None, however, got promoted. The problem, they assert,
    is that several applicants lacking supervisory experience sat
    for the exam, received top scores, and eventually became lieu-
    tenants. Allegedly, the LAPD, the City of Los Angeles, and
    several members of the police force (collectively, the
    "LAPD") waived the experience requirement for these
    favored candidates in violation of the official policy. This
    contention forms the basis of the police officers' substantive
    due process claims, which were brought in April 1994, in an
    action under 42 U.S.C. S 1983.1 In addition, Nunez argues
    that, after he objected to the LAPD's alleged practice of pro-
    moting unqualified applicants, he suffered retaliation. This
    allegation forms the basis of his First Amendment claim, also
    brought pursuant to 42 U.S.C. S 1983.
    
    Upon motion, the district court granted summary judgment
    to the LAPD. Nunez, Gomez, and Vlaskamp timely appealed.
    
    II
    
    As to Gomez, the district court held that the statute of limi-
    tations barred all but one of his substantive due process claims.2
    Gomez applied for the promotion five times -- in 1985, 1987,
    1989, 1991, and 1994 -- and alleges that, every time, the
    LAPD allowed inexperienced candidates to take the examina-
    tion. According to the district court, if this favoritism were
    unconstitutional, Gomez's claims would have accrued one at
    a time when the exams were administered, see Grimes v. City
    and County of San Francisco, 951 F.2d 236, 238-39 (9th Cir.
    1991) (holding that violation accrues when discriminatory act
    occurred); upon accrual, the statute of limitations would have
    started to run. Because the limitations period is only one year,
    see Usher v. City of Los Angeles, 828 F.2d 556, 558 (9th Cir.
    1987), it would have expired well before this action was filed
    in April 1994 -- for all claims except the one arising out of
    the 1994 examination.
    
    Gomez's only response is that the "discovery rule " should
    have tolled the statute of limitations until he had knowledge
    of his injury and its cause. The district court did not disagree.
    Neither do we. However, as Gomez's own deposition unmis-
    takably shows, he had the requisite knowledge as soon as an
    allegedly favored candidate took the exam and got promoted;
    consequently, the discovery rule does not help him:
           Q: When did you first become aware or when did
           you first believe that people who did not have
           the necessary supervisorial experience were sit-
           ting for the lieutenant's exam?
    
           A: I was assigned to internal affairs, and there
           were two women there who were detectives,
           and they were D-II's, Detective II's, working
           with sergeant II's. They both took the lieuten-
           ant's exam and weren't qualified because they
           didn't meet the supervisory requirement,
           passed, and made lieutenant.
    
           Q: When was this?
    
           A: 1985.
    
           . . .
    
           Q: You said that every examination after 1985, that
           there would be people who sat for the lieuten-
           ant's exam who were not qualified?
    
           A: Right, and promoted to lieutenant.
    
           Q: Who were those persons, what year did they sit,
           and when did you find out about that?
    
           A: Every exam, I knew who those people were. 
    
           . . .
    
           Q: So just making sure I understand it, as these
           exams were being administered and at the time
           you were participating in them, you were aware
           of individuals who were sitting for the exam
           who were not qualified?
           A: Yes, sir.
    
    Deposition of Alex Gomez 16-20 (Mar. 20, 1996) (emphasis
    added).
    
    Gomez's own words betray him. He had actual knowledge
    of his alleged injury: inexperienced candidates were taking
    the examination and receiving promotions over him. He also
    had at least presumptive knowledge of the alleged cause of his
    injury, the LAPD's favoritism.3 Despite this overwhelming
    evidence, however, Gomez argues that the district court over-
    looked a genuine issue of fact, which arose when he made
    contradictory statements in a subsequent declaration. Alas,
    not good enough: a party cannot create a triable issue by con-
    tradicting his own sworn testimony. See Radobenko v. Auto-
    mated Equip. Corp., 520 F.2d 540, 543-44 (9th Cir. 1975);
    see also Kennedy v. Allied Mut. Ins. Co., 952 F.2d 262, 266
    (9th Cir. 1991). Finding the subsequent declaration to be a
    sham, the district court correctly held that the only test Gomez
    can challenge is the one administered in 1994.
    
    III
    
    [1] The central question on appeal is whether the LAPD
    violated the police officers' substantive due process rights by
    promoting inexperienced candidates in disregard of official
    policy. The concept of "substantive due process, " semanti-
    cally awkward as it may be, forbids the government from
    depriving a person of life, liberty, or property in such a way
    that "shocks the conscience" or "interferes with rights implicit
    in the concept of ordered liberty." United States v. Salerno,
    481 U.S. 739, 746
      (1987) (quoting, respectively, Rochin v.
    California, 
    342 U.S. 165, 172
      (1952), and Palko v. Connecti-
    cut, 
    302 U.S. 319, 325
     -26 (1937)) (citations and internal quo-
    tation marks omitted).
    
    A
    
    To establish a substantive due process claim, a plaintiff
    must, as a threshold matter, show a government deprivation
    of life, liberty, or property.4See Jeffries v. Turkey Run Con-
    sol. Sch. Dist., 492 F.2d 1, 4 (7th Cir. 1974) (opinion by Ste-
    vens, J.) ("[T]he absence of any claim by the plaintiff that an
    interest in liberty or property has been impaired is a fatal
    defect in her substantive due process argument."). According
    to Nunez, Gomez, and Vlaskamp, the cronyism in the LAPD
    deprived them of both property and liberty. The property
    interest, they contend, is the promotion to lieutenant. The two
    asserted liberty interests are the right to engage in one's cho-
    sen profession and the right "to be free from wholly unreason-
    able and arbitrary" government conduct.
    
    1
    
    [2] Do these police-officer plaintiffs have a property inter-
    est in promotion? Although one's actual job as a tenured civil
    servant is property, see, e.g., Cleveland Bd. of Educ. v.
    Loudermill, 
    470 U.S. 532, 538
     -39 (1985), the prospect of a
    promotion is not in the same category. Several of our sister
    circuits have already reached the issue and rejected attempts
    to classify an expectancy in a promotion as a property interest.5
    See, e.g., Wu v. Thomas, 847 F.2d 1480, 1485 (11th Cir.
    1988); Griffith v. Federal Labor Relations Auth., 842 F.2d
    487, 500-01 (D.C. Cir. 1988); Bigby v. City of Chicago, 766
    F.2d 1053, 1056-57 (7th Cir. 1985); Robb v. City of Philadel-
    phia, 733 F.2d 286, 293 (3d Cir. 1984); Burns v. Sullivan, 619
    F.2d 99, 104 (1st Cir. 1980); Clark v. Whiting, 607 F.2d 634,
    641 (4th Cir. 1979); Schwartz v. Thompson, 497 F.2d 430,
    433 (2d Cir. 1974). On one occasion, so has this court, albeit
    in a cursory manner. See Blevins v. Plummer, 613 F.2d 767,
    768 (9th Cir. 1980) (per curiam).
    
    [3] We see no reason to buck the trend. As the Supreme
    Court has explained, property interests are not created by the
    Constitution, but rather by "existing rules or understandings
    that stem from an independent source such as state law."
    Board of Regents v. Roth, 
    408 U.S. 564, 577
      (1972). In Cali-
    fornia, the terms and conditions of public employment are
    generally "fixed by the statute, rules or regulations creating it,
    not by contract (even if one is involved)." Williams v. Los
    Angeles City Department of Water and Power, 130
    Cal.App.3d 677, 680 (1982); see also Miller v. California, 18
    Cal.3d 808, 813-14 (1977). No such law creates a property
    interest in a promotion. To be sure, the Los Angeles City
    Charter grants tenured police officers "a substantial property
    right" in his "office or position"; however, it merely precludes
    arbitrary "suspen[sions], demot[ions ] in rank, . . . remov[als],"
    or other separation from the LAPD. Charter of the City of Los
    Angeles, Art. XIX, S 202, at 323 (1990). It does not address
    promotions. Cf. Shoemaker v. County of Los Angeles, 37
    Cal.App.4th 618, 632 (1995) ("The civil service rules [of Los
    Angeles County] may have created a legitimate expectation
    that, absent good cause, the County would not terminate
    Shoemaker's employment altogether or impose other disci-
    plinary measures (e.g., demotion) that would adversely affect
    his compensation," but "the County retained the discretion to
    reassign or transfer employees without cause.").
    
    [4] The police officers also direct us to an unpublished con-
    sent decree, known as the "Hunter-LALEA" Consent Decree,
    which was entered into in the Central District of California by
    the City of Los Angeles and litigants from other lawsuits.6
    This agreement established an "affirmative action plan" con-
    sisting, inter alia, of promotion goals for minority police offi-
    cers. Nunez and Gomez, who are Hispanic, suggest that this
    consent decree grants them a property interest in a promotion.
    We disagree. If a consent decree could ever create property
    rights, this is not the one. The agreement, at most, bestows
    rights on a group, not on any individual police officer. Indi-
    vidual applicants for a promotion must still establish qualifi-
    cation. Moreover, the city may use any qualification device
    not expressly barred, so the LAPD's written and oral tests are
    permissible.
    
    [5] To have a property interest, "a person clearly must have
    more than an abstract need or desire." Roth, 
    408 U.S. at 577
    .
    A mere "unilateral expectation" of a benefit or privilege is
    insufficient; the plaintiff must "have a legitimate claim of
    entitlement to it." Id. When the police officers sat for the lieu-
    tenants examination, notwithstanding the Consent Decree, any
    possibility of promotion was contingent upon their success on
    the exam, as well as upon the number of lieutenant positions
    available. Such contingencies belie the claim that the police
    officers had even so much as a reasonable expectation of
    being promoted. Even if the police officers anticipated a pro-
    motion, any expectations were just that, and nothing more.
    They did not rise to the level of entitlements; they were "not
    so firm and definite . . . as to be `property' in a constitutional
    sense." Bigby, 766 F.2d at 1056. Until someone actually
    receives a promotion, or at least a binding assurance of a
    forthcoming promotion,7 he cannot claim a property interest
    in the promotion. Group preferences, which merely establish
    group goals, do not suffice. Thus, the police officers have
    failed to establish a property interest in a promotion.8
    
    2
    
    The police officers also contend that they were deprived of
    two liberty interests: a right to engage in one's chosen profes-
    sion and a right to be free from arbitrary and capricious gov-
    ernment action. We address them in turn.
    a
    
    [6] First, to be sure, there is a centuries-old concept of lib-
    erty of occupation. See Bigby, 766 F.2d at 1057 (citations
    omitted). However, there is no similar notion of liberty of
    position or rank within an occupation. See id. Moreover, the
    Supreme Court held in Roth that a person has not suffered a
    deprivation of liberty "when he simply is not rehired in one
    job but remains as free as before to seek another " within his
    chosen industry, Roth, 
    408 U.S. at 575
    ; it follows, a fortiori,
    that there cannot be a deprivation of liberty when even the
    person's current job is still available to him. As long as
    employment options within the profession remain, no due
    process interests have been implicated. Unsurprisingly, every
    circuit that has addressed the issue has rejected the claim that
    the denial of a promotion constitutes a deprivation of liberty.
    See, e.g., Wu, 847 F.2d at 1485; Bigby, 766 F.2d at 1057;
    Robb, 733 F.2d at 293-94; Beitzell v. Jeffrey, 643 F.2d 870,
    877-78 (1st Cir. 1981); Clark, 607 F.2d at 641-42; Blevins,
    613 F.2d at 768; Schwartz, 497 F.2d at 431-32. We agree with
    this consensus. Whereas "preventing someone from advanc-
    ing in his occupation can be a cruel deprivation, it would
    stretch the idea of liberty of occupation awfully far . . . to treat
    a bar to promotion as a deprivation of that liberty. " Bigby, 766
    F.2d at 1057.
    
    b
    
    [7] The second liberty interest asserted by the police offi-
    cers is the right "to be free from wholly unreasonable and
    arbitrary" government conduct bearing no relation to the pub-
    lic health, welfare, safety, and morals. Unfortunately for the
    police officers, the Supreme Court has already explained that
    a court has "no license to invalidate legislation which it thinks
    merely arbitrary or unreasonable." Regents of University of
    Michigan v. Ewing, 
    474 U.S. 214, 226
      (1985) (quoting Moore
    v. East Cleveland, 
    431 U.S. 494, 543
     -44 (1977) (White, J.,
    dissenting)); see also Albright v. Oliver, 
    510 U.S. 266
    , 272
    (1974). There is no general liberty interest in being free from
    capricious government action. See Jeffries v. Turkey Run Con-
    sol. Sch. Dist., 492 F.2d 1, 4, n.8 (7th Cir. 1974) (opinion by
    Stevens, J.). Otherwise, as then-Judge Stevens explained,
    "every time a citizen [i]s affected by governmental action, he
    would have a federal right to judicial review." Id. Put simply,
    not every social injustice has a judicial remedy. See Bishop v.
    Wood, 
    426 U.S. 341, 349
      (1976) ("The federal court is not the
    appropriate forum in which to review the multitude of person-
    nel decisions that are made daily by public agencies."). The
    federal judiciary is not a good-government watchdog; the Due
    Process Clause is not the "Fairness Clause."
    
    [8] Thus, the police officers have not even arrived at the
    substantive due process threshold. They have asserted no cog-
    nizable property or liberty interest.
    
    B
    
    [9] Moreover, we note that, even if there were a constitu-
    tionally protected property or liberty interest in a promotion,
    which there is not, the police officers still could not prevail.
    The Due Process Clause takes effect only if there is a
    deprivation of a protected interest. The police officers have
    not shown any causal connection between the government's
    alleged cronyism and their failure to be promoted.
    
    [10] Nunez took the exam only once, in 1994. Although he
    demonstrated that three of the applicants that year lacked the
    requisite experience to take the exam, none of the three was
    promoted to the position of lieutenant, or even allowed to fin-
    ish the exam. Thus, even if the LAPD had a secret policy of
    letting favored unqualified applicants sit for the exam, this
    policy did not preclude Nunez from being promoted.
    
    [11] Gomez took the examination five times. However, as
    explained above, any claims arising from the 1985, 1987,
    1989, and 1991 exams are barred by the statute of limitations.
    
    The only surviving claim is the one arising out of the 1994
    test. Gomez cannot show causation with regard to this exam
    for two reasons: first, as discussed above, there is no evidence
    that any inexperienced candidates were promoted that year;
    and second, Gomez received a failing score on the written
    exam, 56.1%, which made him ineligible for a promotion.
    
    [12] Vlaskamp sat for the exam twice, but finished it only
    once, in 1989.9 The district court noted that he "failed to pro-
    vide . . . any competent admissible evidence demonstrating
    any unqualified individuals were allowed to take the 1989
    lieutenant's examination." Vlaskamp did not challenge this
    conclusion on appeal.
    
    [13] Thus, Nunez, Gomez, and Vlaskamp have failed to
    show any government deprivation of a protected property or
    liberty interest. The LAPD has not violated the police offi-
    cers' substantive due process rights.10 
    
    IV
    
    Nunez also raises a First Amendment claim. After discov-
    ering that inexperienced candidates sat for the 1994 examina-
    tion, he complained to the Office of the Chief of Police, the
    City Ethics Commission, the City Personnel Department, and
    the Board of Police Commissioners. Nunez alleges that,
    because of these protests, his superiors retaliated by scolding
    him and threatening to transfer or to dismiss him.
    [14] To succeed on a wrongful-retaliation claim, a plaintiff
    must show, in the first instance, that he has suffered an
    adverse employment action. See Pierce v. Texas Dept. of
    Criminal Justice, 37 F.3d 1146, 1149 (5th Cir. 1994); Hyland
    v. Wonder, 972 F.2d 1129, 1134-36 (9th Cir. 1992). Only then
    do we address whether the statement which motivated the
    retaliation is one of public concern and whether the interests
    of the employee outweigh the state's interest in maintaining
    efficient public services. See id. at 1136-40. Although "the
    type of sanction . . . `need not be particularly great in order
    to find that rights have been violated,' " Hyland, 972 F.2d at
    1135 (quoting Elrod v. Burns, 
    427 U.S. 347
    , 359 n.13
    (1976)); see also Manhattan Beach Police Officers Ass'n v.
    City of Manhattan Beach, 881 F.2d 816, 818-19 (9th Cir.
    1989) (denial of promotion); Allen v. Scribner, 812 F.2d 426,
    434-35 (9th Cir. 1987) (transfer to less desirable job assign-
    ment), the plaintiff must nonetheless demonstrate the loss of
    "a valuable governmental benefit or privilege."11 Hyland, 972
    F.2d at 1136. Mere threats and harsh words are insufficient.
    See Pierce, 37 F.3d at 1150; cf. Gini v. Las Vegas Metropoli-
    tan Police Depart., 40 F.3d 1041, 1045 (9th Cir. 1994)
    ("[D]amage to reputation is not actionable under S 1983
    unless it is accompanied by `some more tangible interests.' ")
    (quoting Paul v. Davis, 
    424 U.S. 693, 701
      (1976)).
    
    [15] Nunez's claim does not survive this threshold inquiry.
    Not only has he retained his job, he has suffered no adverse
    employment action whatsoever. Despite the alleged efforts of
    his superiors, Nunez never signed or verified any allegedly
    false reports, which could have triggered an official repri-
    mand. Moreover, although the LAPD did not select him for
    promotion, Nunez has not provided any evidence linking this
    decision to his criticisms.12 All he has shown is that he was
    bad-mouthed and verbally threatened. It would be the height
    of irony, indeed, if mere speech, in response to speech, could
    constitute a First Amendment violation. Thus, Nunez's First
    Amendment claim fails.
    
    AFFIRMED.
    
    _________________________________________________________________
    
    FARRIS, Circuit Judge, Concurring:
    
    I concur. The result is dictated by ample authority that the
    plaintiffs have no property interest in a promotion under the
    present facts. Despite this authority, the defendants should not
    read the opinion as giving them carte blanche to ignore estab-
    lished procedures where substantial interests are at stake. This
    is simply a matter to which the federal substantive due pro-
    cess clause does not speak.
    
    I am satisfied that the facts of this action did not warrant
    recovery under the due process clause. Nonetheless, I concur
    with the caution that the opinion not be misconstrued.
    _______________________________________________________________
    
    FOOTNOTES
    
    1 The police officers originally claimed violations of their procedural
    due process and equal protection rights. However, they dropped these con-
    tentions on appeal.
    2 Intriguingly, Vlaskamp also contends that the district court erroneously
    held his claims to be time-barred. The district court did not so hold.
    Rather, it tolled the statute of limitations under the "discovery rule" and
    then proceeded to reject Vlaskamp's claims on the merits.
    3 Under California law, " `presumptive' as well as `actual' knowledge
    will commence the running of the statute [of limitations]." Sanchez v.
    South Hoover Hosp., 18 Cal.3d 93, 101 (1976). If a plaintiff has "notice
    or information of circumstances to put a reasonable person on inquiry,"
    the statute runs. Id. (quoting 2 Witkin, Cal. Procedure (2d ed. 1970)
    Actions, S 339, at 1181) (internal quotation marks omitted).
    4 Obviously, merely showing such deprivation is not enough to prevail.
    "The protections of substantive due process have for the most part been
    accorded to matters relating to marriage, family, procreation, and the right
    to bodily integrity." Albright v. Oliver, 
    510 U.S. 266, 272
      (1994). These
    fields likely represent the outer bounds of substantive due process protec-
    tion. See Collins v. City of Harker Heights, 
    503 U.S. 115, 125
      (1992)
    ("[T]he Court has always been reluctant to expand the concept of substan-
    tive due process because guideposts for responsible decisionmaking in this
    unchartered area are scarce and open-ended.").
    5 The Sixth Circuit once reversed a district court which found no prop-
    erty interest in a promotion; however, it did so only because the district
    court dismissed the employee's claim on the pleadings without regard to
    the employee's argument that he had an implied contract entitling him to
    a promotion. See Paskvan v. City of Cleveland Civil Serv. Comm'n, 946
    F.2d 1233, 1235-36 (6th Cir. 1991). Moreover, the Sixth Circuit expressed
    doubt that the employee could satisfy his "heav[y] burden" on remand. Id.
    at 1236.
    6 Hunter was the named plaintiff in one suit. "LALEA" stands for the
    
    7 When permitted by state law, this commitment need not be formally
    expressed in a statute or a written contract; it can be implied from words
    or conduct. See Perry v. Sindermann, 
    408 U.S. 593, 601
     -02 (1972). Never-
    theless, there must be rules or mutually clear understandings securing the
    commitment. See id. at 601.
    8 Nor do the plaintiffs have a property interest in the procedures for pro-
    moting candidates to lieutenant. Procedural requirements can give rise to
    property interests only when they impose "significant limitation[s] on the
    discretion of the decision maker." Goodisman v. Lytle, 724 F.2d 818, 820
    (9th Cir. 1984). The procedures in the Los Angeles City Charter do not
    meet this standard. They merely state that promotions are to be based on
    "ascertained merit and seniority." Charter of the City of Los Angeles, Art.
    IX, S 107, at 124. Establishing "only an outline of relevant considera-
    tions," Goodisman, 724 F.2d at 821, the charter does very little to elimi-
    nate the discretion of those who evaluate candidates on the oral portion of
    the lieutenants examination. Moreover, although the Manual of the Los
    Angeles Police Department imposes an experience requirement on appli-
    cants, it does not significantly reduce this discretion; as the LAPD notes
    (and the police-officer plaintiffs do not deny), it "relies predominantly on
    subjective oral examinations" in selecting officers for promotion.
    9 Vlaskamp chose not to take the oral portion in 1991 even though he
    had passed the written portion.
    10 Contrary to the police officers' assertions, the failure to establish
    injury and causation defeats their "Monell claim" against the City of Los
    Angeles, as well as their S 1983 claims against the other defendants.
    Under Monell v. Department of Social Services, 
    436 U.S. 658
     (1978), to
    sustain a S 1983 action against a municipality, a plaintiff must demonstrate
    that a governmental policy or custom has caused him injury. See id. at
    691-94. Even if Los Angeles had a policy or custom of promoting unquali-
    fied favorites, that policy or custom could not have caused any injury, for
    the reasons explained above.
    11 Unlike Due Process claims, First Amendment claims need not estab-
    lish an entitlement to the government benefit or privilege. See Perry, 408
    U.S. at 597. "[E]ven though a person has no`right' to a valuable govern-
    ment benefit," the government "may not deny[the] benefit . . . on a basis
    that infringes his constitutionally protected interests -- especially, his
    interest in freedom of speech." Id.
    12 Nunez has not even shown that his score on the oral portion of the
    exam was downgraded on account of his speech. Indeed, his oral test score
    of 86.5% was significantly higher than his barely passing score on the
    written portion of the test, 65.9%. the end