Knight v. Connecticut Department of Public Health involved separate claims by a nurse and sign language interpreter who were reprimanded for proselytizing to clients while on the job. The workers claimed that the First Amendment guaranteed their right to discuss their religious views while at work. The United States Court of Appeals for the Second Circuit found that the government restrictions on the workers’ speech were reasonable, and did not violate the Free Exercise Clause. The court noted that the state's role as sovereign constrains its ability to regulate religious speech, while its role as employer provides it with greater leeway to control employees' speech that threatens to undermine its ability to perform its legitimate functions. This means that certain restrictions that might violate the Free Exercise Clause as applied to non-government employees might be constitutional as applied to individuals performing duties on behalf of the government. Because both individuals in this case were discussing their religious beliefs while conducting government business, the court upheld the regulations under which the individuals were reprimanded.
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