granted the request in 1993. Supreme Court Before the Court The federal government filed an amicus curiae brief urging reversal, along with the International City/County Management Association. Amici urging affirmance came from the National Education Association and Southern States Police Benevolent Association. The National Employment Lawyers Association (NELA) filed an amicus brief on behalf of Petitioners, Waters, et al.. In it, NELA's counsel of record argued, inter alia, that the firing of a public employee for uttering speech subjectively deemed by a public employer to be deemed "insubordinate" is an unconstitutionally vague and overbroad employment of the employees First Amendment rights. Oral arguments were heard in December 1993. Lawrence Manson, arguing for the hospital and other original defendants as petitioners, was joined by assistant Solicitor General Richard Seamon. John Bisbee, who had represented Churchill and Koch from the beginning, argued their case. Manson began by attacking the Seventh Circuit's "unprecedented holding". Churchill, he argued, had to show that the defendants were aware that her speech was protected. "[A]ll the defendants knew about was comments of personal matters, grievances against the supervisor." He quoted at length from Ballew's deposition to support that contention. If Churchill had wanted to contest the veracity of Ballew's report, she had the opportunity to do so when Davis fired her, but chose not to do so. The justices challenged him at length on the implications of that theory, whether it would apply to a more clear-cut situation where the employer had acted on mistaken information. Manson insisted that under the Mt. Healthy rule that would not be a violation of the First Amendment. He also insisted that it covered a case where the motive for the firing was clearly the speech and not any other associated conduct. Seamon, too, was questioned on this as well, with the same result. "[I]n an employment at will situation like this one, the Government can discharge an employee for any reason or no reason at all, as long as it is not motivated by a desire to retaliate against the employee for engaging in protected speech." Bisbee was asked the same question, but preferred to focus on the facts of his case. He stressed that "[w]hat was reported to them was basically a headline: 'Things were bad in OB and the administration was responsible.'" Justice Sandra Day O'Connor asked about the Pickering test: "Do you think that even protected speech