On April 14, 2010, the Third Circuit Court of Appeals affirmed summary judgment in favor of Chalfont Borough in Knight v. Drye et al. where the Plaintiff police officer claimed that Borough officials unlawfully terminated him in retaliation for allegedly complaining about fellow officers' misconduct.  Since Knight claimed that his complaints were made within the course of his duties through the chain of command, the Court ruled that his speech is not protected by the First Amendment.  The Court explained that speech may be protected under the First Amendment only when expressed by citizens outside the scope of government employment.  The Knight decision should insulate local governments in the Third Circuit from similar lawsuits in the future.