Under Pickering v. Board of Educ., 391 U.S. 563, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968), the court must balance the state's interest in an efficient and effective school system with a teacher's right as a citizen to speak out on matters of public concern. "The problem in any case is to arrive at a balance between the interests of the teacher, as a citizen, in commenting upon matters of public concern and the interest of the State, as an employer, in promoting the efficiency of the public services it performs through its employees." Pickering, 391 U.S. at 568, 88 S.Ct. at 1734. The Pickering Court considered a number of factors and determined that the plaintiff's speech was protected because: (1) it was not directed at anyone with whom Pickering had contact on a daily basis; (2) Pickering's employment did not require personal loyalty to the school board or superintendent; (3) the speech did not disrupt harmony among his co-workers; (4) Pickering's immediate supervisors' ability to maintain discipline was not negatively affected by the speech. Id. at 569-70, 88 S.Ct. at 1735-36.