further discussion, when such disputes arise." In conclusion, he said, the First Amendment "requires that, before firing a public employee for her speech, management get its facts straight." Subsequent jurisprudence The next term, in United States v. National Treasury Employees Union, a 6–3 Court held unconstitutional Section 501(b) of the Ethics Reform Act of 1989 (), which barred all federal employees from accepting compensation for making speeches or writing for publication. Stevens, writing for the majority, distinguished the case from Waters and its predecessors by noting that it involved a broadly applied instance of prior restraint instead of a disciplinary action against a single employee for actual speech. Following Waters he found the government's predictions of disruption if the statute were overturned unwarranted. O'Connor wrote a separate concurrence noting that this case was an instance of the limits on deference to the government as employer she had recognized in Waters. "As the magnitude of intrusion on employees' interests rises, so does the Government's burden of justification ... In this case ... the Government has exceeded the limits of its latitude". Chief Justice William Rehnquist, writing for the dissenters, argued that the majority overemphasized the Waters test at the expense of the balancing of individual and government interests required by Pickering. Heffernan v. City of Paterson While the Court heard other cases concerning the First Amendment rights of public employees, it would not revisit Waters until Heffernan v. City of Paterson in 2016. There, a New Jersey police detective sued his employer after he was demoted to patrol work due to a mistaken belief that he was supporting an opposing candidate in the city's mayoral election. "In Waters, the employer reasonably but mistakenly thought the employee had not engaged in protected speech," Justice Stephen Breyer wrote, distinguishing the two cases. "Here, the employer mistakenly thought the employee had ...." Since, in Waters, the Court had concluded that the employer's intent was what mattered, Breyer argued Heffernan should be decided the same way. "In law, what's sauce for the goose is sauce for the gander," he wrote. Breyer and five other justices held for Heffernan that his discipline violated constitutional rights he had not exercised. Appeals courts Waters has also been cited many times by lower courts. At the appellate level, there have been several notable cases where it has factored into the analysis, sometimes helping to decide the case, and in