Federal courts have had over two decades since Connick v Myers to apply the Pickering-Connick shifting burden of proof tests to numerous education cases. However, nothing tends to remain static in American law and its most recent free speech case, Garcetti v Ceballos (Garcetti), the Supreme Court has further refined the expressive rights of employees. Although not an education case, Garcetti, like Connick before it, has already had an impact on teacher expression. The purposes of this article are broadly twofold: to briefly review the facts and the Supreme Court decision in Garcetti; and, to explore the application of Garcetti to the expression of K-12 teachers.