The 9th Circuit ruled an Oregon school counselor's book display promoting binary gender views was government speech, not protected by the First Amendment.
https://www.foxnews.com/media/fired-school-counselor-loses-again-after-free-speech-fight-over-gender-themed-books-his-office
https://www.foxnews.com/media/fired-school-counselor-loses-again-after-free-speech-fight-over-gender-themed-books-his-office