The Warren Court ruled in its 1968 decision Pickering v. Board of Education that school district officials in Will County, Illinois, violated the First Amendment rights of public school teacher Marvin Pickering when they fired him for writing a letter to a local newspaper criticizing the school district’s allocation of finances. The Court ruled that “a teacher’s exercise of his right to speak on issues of public importance may not furnish the basis for his dismissal from public employment.” The Court created the Pickering test which provides that public employees’ right to speak on matters of public concern must be weighed against a public employer’s efficiency interests.