dissent argued that the First Amendment required that the lower court determine exactly what Churchill had said before ruling on whether it was protected. Outside commentators have also been critical of the decision, since it might discourage whistleblowers. In addition to echoing Stevens' concerns, they have seen it as abandoning any concern for the truth, imposing a heavy burden on a plaintiff, relying on an overly narrow conception of the public's interest, and possibly discouraging people from entering public service. The decision resulted in a lower court changing its ruling in a high-profile case involving controversial academic Leonard Jeffries. Dispute Churchill had been hired as a part-time nurse at McDonough in 1982, and promoted to full-time status three years later. She worked for the next two years in the obstetrics ward. She had generally received favorable performance evaluations until Waters became her supervisor in the middle of 1986. That happened a few months after Kathy Davis took over as the hospital's vice president of nursing. Waters had been implementing Davis's policy of cross-training, under which nurses were in areas overstaffed on a particular shift were reassigned to departments that needed more nurses. Churchill was one of several employees who had voiced objections to the way the policy was being implemented. She and other critics feared that it was primarily being used to address staffing shortages without providing adequate training, with detrimental effects on patient care. Churchill's criticisms had been long voiced by one of the hospital's obstetricians, Dr. Thomas Koch. During a 1982 malpractice suit he had blamed a stillbirth on nursing shortages created, he alleged, by hospital policies, and had continued the criticism since then. Churchill and he became friends and allies, with her providing inside information on nursing policies that he then used to criticize the administration. She believed this incurred her the enmity of administrators who were by summer of 1986 keeping a file of criticisms of Koch made by Davis and nursing supervisor Cindy Waters. That August, an incident occurred that bore out Churchill and Koch's concerns, and began the sequence of events that led to the lawsuit. During a difficult delivery, Koch called for a "Code pink" emergency, indicating danger to the life of mother and/or child. A probationary nurse, Mary Lou Ballew, did not know how to properly signal the emergency and did not alert all the necessary personnel. Churchill responded and helped Koch