Piscottano v. Murphy

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    05-3716-cv Piscottano v. Murphy 1 UNITED STATES COURT OF APPEALS 2 FOR THE SECOND CIRCUIT 3 - - - - - - 4 August Term, 2005 5 (Argued: February 14, 2006 Decided: December 21, 2007) 6 7 Docket No. 05-3716-cv 8 _________________________________________________________ 9 GARY PISCOTTANO, MARK J. VINCENZO, WALTER C. SCAPPINI 10 II, and JAMES KIGHT, 11 Plaintiffs-Appellants, 12 - v. - 13 BRIAN MURPHY, Deputy Commissioner, Department of 14 Correction, individually, and THERESA C. LANTZ, 15 Commissioner, Department of Correction, individually 16 and in her official capacity, 17 Defendants-Appellees. 18 _________________________________________________________ 19 Before: KEARSE and SACK, Circuit Judges, and STANCEU, Judge*. 20 Appeal from a judgment of the United States District Court 21 for the District of Connecticut dismissing complaint alleging that 22 discipline of state correctional officers for association with the 23 Outlaws Motorcycle Club violated their rights under the First and 24 Fourteenth Amendments to the Constitution. 25 Affirmed. *Honorable Timothy C. Stanceu, of the United States Court of International Trade, sitting by designation. 1 KATHLEEN ELDERGILL, Manchester, Connecticut 2 (Beck & Eldergill, Manchester, Connecticut, on 3 the brief), for Plaintiffs-Appellants. 4 GREGORY T. D'AURIA, Associate Attorney General, 5 Hartford, Connecticut (Richard Blumenthal, 6 Attorney General of the State of Connecticut, 7 Margaret Q. Chapple, Assistant Attorney 8 General, Hartford, Connecticut, on the brief), 9 for Defendants-Appellees. 10 KEARSE, Circuit Judge: 11 Plaintiffs Gary Piscottano, Mark J. Vincenzo, Walter C. 12 Scappini II, and James Kight, who are current or former employees of 13 the Connecticut Department of Correction ("DOC" or the 14 "Department"), appeal from a judgment of the United States District 15 Court for the District of Connecticut, Mark R. Kravitz, Judge, 16 dismissing their claims that the defendant DOC officials violated, 17 inter alia, their First Amendment and due process rights to freedom 18 of expressive association and freedom of intimate association by 19 disciplining them on account of their membership in, and their 20 association with members of, the Outlaws Motorcycle Club, pursuant 21 to a Department regulation that plaintiffs contend is impermissibly 22 vague. The district court granted summary judgment dismissing those 23 claims on the grounds that plaintiffs' membership in the Outlaws 24 Motorcycle Club did not constitute expressive association on matters 25 of public concern, that membership in that organization is not an 26 intimate relationship that warrants constitutional protection, and 27 that the pertinent regulation is not unconstitutionally vague as 28 applied to plaintiffs. On appeal, plaintiffs contend principally 29 that the district court erred (1) in finding the "public concern" 30 test applicable to their expressive association claims and failing -2- 1 to find that a balancing of the parties' respective interests 2 favored plaintiffs; (2) in failing to find that defendants' actions 3 burdened plaintiffs' intimate personal relationships; and (3) in 4 failing to find the Department regulation void for vagueness as 5 applied. For the reasons that follow, we reject all of plaintiffs' 6 contentions and affirm the judgment. 7 I. BACKGROUND 8 For purposes of defendants' motion for summary judgment, 9 the following facts, many of which were the subject of testimony at 10 a preliminary injunction hearing, see Piscottano v. Murphy, 317 11 F.Supp.2d 97 (D. Conn. 2004) ("Piscottano I"), were largely 12 undisputed. 13 Prior to April 2004, plaintiffs were employed by DOC as 14 correctional officers in various prisons in the State of Connecticut 15 ("State"). Piscottano had been so employed for approximately 18 16 years, Vincenzo for 18½ years, Scappini for 9 years, and Kight for 17 11½ years. In April 2004, following a hearing for each plaintiff 18 pursuant to Cleveland Board of Education v. Loudermill, 470 U.S. 19 532, 538-41 (1985) ("Loudermill hearing"), DOC terminated the 20 employment of Piscottano and Kight, and ordered counseling for 21 Vincenzo and Scappini, on account of their association with the 22 Outlaws Motorcycle Club (or "OMC," "Outlaws," or "Club"). In 23 November 2004, Vincenzo was discharged after a further Loudermill 24 hearing. 25 Defendant Theresa C. Lantz, with nearly three decades of -3- 1 experience in prison administration as, inter alia, correctional 2 officer, counselor, training manager, warden, and deputy 3 commissioner, became DOC's Commissioner in March 2003. Defendant 4 Brian Murphy, who had two decades of experience as, inter alia, 5 correctional officer, warden, director of prison security, and 6 expert on gangs, became DOC's Deputy Commissioner for Operations in 7 April 2003. The disciplines imposed on plaintiffs were recommended 8 by Murphy; the final decisions to impose those disciplines were made 9 by Lantz. 10 A. Early Law-Enforcement Information Regarding the Outlaws 11 Although the proceedings leading to the disciplining of 12 plaintiffs had their immediate impetus in an anonymous letter 13 received by DOC in July 2003 (see report of DOC's Security Division 14 dated September 18, 2003 ("DOC 2003 Report" or "DOC Report"), 15 described in Part I.B. below), local and federal law enforcement 16 agencies had been investigating the Outlaws long before the receipt 17 of that letter. 18 1. Information from the Federal Government 19 According to the National Drug Intelligence Center 20 ("NDIC"), which is a unit of the United States Department of 21 Justice, the Outlaws Motorcycle Club has been in existence since 22 1935 and has multiple chapters in the United States, Canada, Europe, 23 and Australia. An October 2002 report of NDIC ("NDIC Report"), 24 received by DOC, contained descriptions of Outlaws activities and 25 the results of investigations by the Bureau of Alcohol, Tobacco, and -4- 1 Firearms ("BATF") and the Federal Bureau of Investigation ("FBI"). 2 According to the NDIC Report, the OMC is involved in the 3 unlawful production and distribution of methamphetamines and in the 4 transportation and distribution of ecstasy, marijuana, and cocaine. 5 Florida chapters obtain kilogram quantities of cocaine directly from 6 Colombian drug trafficking organizations. Other chapters obtain 7 100-pound quantities of marijuana from Mexico. As a result of BATF 8 and FBI investigations, key officers and members of the Outlaws have 9 been prosecuted for and convicted of various crimes; at the time of 10 the NDIC Report, more than 100 Outlaws members were imprisoned in 11 federal facilities. For example, a 1997 RICO prosecution in 12 Wisconsin led to the conviction of 17 Outlaws members on charges 13 involving bombings, robberies, and six murders during a span of five 14 years. A 2001 RICO trial in Florida revealed a decade-long campaign 15 of terror, using murder, bombings, and other forms of intimidation 16 to control the Club's lucrative cocaine trade in Florida; that trial 17 resulted in the conviction of the Outlaws international president, 18 who was sentenced to two consecutive terms of life imprisonment. 19 The NDIC Report stated that Outlaws members also engage in 20 other criminal activities including assault, kidnaping, weapons and 21 explosives violations, arson, theft of motorcycles and motorcycle 22 parts, fraud, money laundering, and extortion. The OMC is involved 23 in the sale of stolen motorcycle parts and in the exploitation of 24 female associates as prostitutes. It launders proceeds of its 25 illegal activities through, inter alia, the sale of Club merchandise 26 at sponsored events. 27 The NDIC Report also stated that the Outlaws has a history -5- 1 of violent rivalry with the Hells Angels Motorcycle Club ("Hells 2 Angels" or "HAMC"), involving incidents of bombing, arson, and 3 murder. Although the Hells Angels had viewed the northeastern 4 United States as its own territory, the report noted that newly 5 established Outlaws chapters in the United States 6 includ[ed] 8 chapters in the HAMC-controlled states 7 of Connecticut, Massachusetts, New Hampshire and New 8 York. This expansion as well as reports of 9 stockpiling weapons and body armor in preparation 10 for confrontations has heightened tensions between 11 OMC and HAMC. 12 The report noted that 23 heavily armed Outlaws members who were 13 preparing for a fight with the Hells Angels had been arrested in 14 Revere, Massachusetts, on February 23, 2002. 15 2. Information from State and Local Police Forces 16 In 2002, DOC became aware that the Outlaws had opened a 17 chapter in Waterbury, Connecticut. Officers of the Waterbury Police 18 Department and the State Police conducted surveillance of an Outlaws 19 "coming out" party in Waterbury in May 2002. The police 20 investigation included checking the registrations of the motor 21 vehicles parked at the Outlaws compound. Those inquiries revealed 22 that two of the vehicles belonged to Kight and Scappini; the address 23 of their registrations was the Webster Correctional Institution 24 ("Webster CI"), the DOC facility at which Kight and Scappini were 25 correctional officers. The police relayed this information to DOC. 26 Other police surveillances were conducted of Outlaws 27 parties held on various dates in 2003, including May 24, July 17, 28 and September 6. The police sent videotapes and still photographs 29 to DOC's Security Division ("Security Division" or "SD"), showing -6- 1 Piscottano, Vincenzo, Scappini, and Kight at one or more of those 2 parties. Murphy testified that he first became aware that certain 3 correctional officers might be involved with the Outlaws in May 4 2003, when a reporter for a major Connecticut newspaper made a 5 freedom-of-information inquiry of DOC. (See Preliminary Injunction 6 Hearing Transcript ("Tr.") at 222, 269.) The reporter requested 7 information concerning DOC investigations, including those with 8 respect to Piscottano, Vincenzo, and Kight. (See DOC 2003 Report at 9 2.) 10 DOC received information about the Outlaws and its 11 activities from State Police Trooper Richard Williams, who had long 12 experience in investigating so-called "one-percent" motorcycle 13 gangs--a term derived from an American Motorcycle Association 14 official's remark in the 1950s that 99 percent of all bikers were 15 law-abiding, and thus "only" one percent of the motorcycles on the 16 roads belonged to persons who were trouble-makers. Williams 17 informed DOC that the OMC is a self-proclaimed one-percent gang; 18 that, like other one-percent motorcycle clubs, the Outlaws has 19 distinctive patches that members wear on their clothing, including 20 a "1%" patch; that these patches, known as "colors," signify 21 membership in the Club; that their colors are a source of pride and 22 are not loaned out; that the colors must be returned if the member 23 leaves the Club, unless he has been a member in good standing for 24 more than a few years; that women cannot be members of the Club, but 25 wives and girlfriends are allowed to wear "Property of the Outlaws" 26 colors; and that these colors, too, must be returned if the member 27 leaves the Club, unless he has been a member for a long period. -7- 1 Williams testified that he had received information from 2 law enforcement agencies around the country about illegal activities 3 of the Outlaws. These included narcotics trafficking, prostitution, 4 rape, and murder. 5 DOC was informed by Williams and the Waterbury police of 6 a drive-by shooting that took place on June 29, 2003. According to 7 Williams, several shots were fired, including two into the door of 8 a social club located in a building that also housed the Outlaws 9 Motorcycle Club. According to the police incident report, a witness 10 stated that the shooter was a white male in his 30s; that after the 11 shots were fired, members of the Outlaws came running out and 12 inquired about the color of the car and the driver; and that when 13 the witness told them the car was dark and the driver was a white 14 male, the Outlaws appeared to know who the shooter had been. 15 B. The July 6, 2003 Anonymous Letter and DOC's Investigation 16 On July 6, 2003, a week after the June 29 drive-by 17 shooting, Lantz received an anonymous letter stating, inter alia, 18 that the Outlaws, described as arch rivals of the Hells Angels, had 19 recently established a chapter in Connecticut, and predicting that 20 there would ensue an "all out gang war in the Waterbury area this 21 summer and innocent people are going to get hurt because of them" 22 (Anonymous Letter). The letter stated that at least five DOC 23 correctional officers were members of the Outlaws, including one 24 named "Gary," whose last name the author did not know, and another, 25 whose name might be "Jim Kite," who had threatened another person 26 with a gun in a road-rage incident. (Id.) The letter referred to -8- 1 "[t]hese men" as "1% outlaw motorcycle club members" who, while 2 having their salaries and pensions funded by the citizenry, were 3 "terrorizing" "the citizens . . . in Waterbury and elsewhere in Ct." 4 (Id.) 5 A DOC regulation prohibits DOC employees from, inter alia, 6 "[e]ngag[ing] in conduct that constitutes, or gives rise to, the 7 appearance of a conflict of interest," and "[e]ngag[ing] in 8 unprofessional or illegal behavior, both on and off duty, that could 9 in any manner reflect negatively on the Department of Correction." 10 See DOC Administrative Directive 2.17, Employee Conduct ("Directive 11 2.17"). Lantz forwarded the Anonymous Letter to Murphy and to SD, 12 the DOC unit responsible for investigating questions of serious 13 staff misconduct, for further review. 14 On July 12, 2003, SD investigator Luis Irizarry conducted 15 surveillance of a party at the Outlaws Waterbury clubhouse. He 16 observed Piscottano, Vincenzo, and Kight at that event. In August 17 2003, Lantz ordered a formal investigation into the Anonymous 18 Letter's allegations. 19 1. DOC's September 2003 Interviews of Plaintiffs 20 In September 2003, the Security Division conducted 21 interviews of Piscottano, Kight, Vincenzo, and Scappini. Piscottano 22 and Kight stated that they had been members of the Outlaws for a 23 time but had resigned; Vincenzo and Scappini denied ever having been 24 members of the Outlaws. All stated that they had attended Outlaws 25 functions even as non-members. The ensuing DOC report included the 26 following descriptions of the interviews. -9- 1 Piscottano stated that he had been a member of the 2 Outlaws, initially probationary and then full-fledged, for a total 3 of about a year; he resigned his membership in the Outlaws in the 4 spring of 2003. He stated that he had attended a number of Outlaws 5 functions during the summer of 2003. Piscottano stated that he knew 6 that Randy Sabettini (a correctional officer who was also originally 7 a plaintiff in this action) had at one time been a member of the 8 Outlaws, but did not know of any other correctional officers who 9 were members. Piscottano stated that he "d[id] not know that the 10 Outlaws [we]re involved in any criminal activity," and said, "if 11 they were I wouldn't be there." Further, taken in the light most 12 favorable to Piscottano, the record indicates that he had been 13 informed by Sabettini prior to September 2003 that Sabettini had 14 inquired of, and received assurances from, DOC supervising officials 15 that an officer's association with the Outlaws would not pose a 16 problem so long as the officer himself was not involved in criminal 17 activity. 18 Kight, in his interview, stated that after a six-month 19 probationary period, he had become a full member of the Outlaws in 20 September 2002. He took a leave of absence in June 2003, and he 21 officially resigned in July 2003 and turned in his colors. He 22 stated that he had attended some Outlaws functions after resigning 23 from the Club, most recently in the week before his interview. He 24 knew that Piscottano had been a member of the Outlaws. 25 Kight said he was "not aware of any illegal activity by 26 any of the members of the club . . . . There may be criminal 27 activity in other states but none in Connecticut as far as [he] -10- 1 kn[e]w." He also stated that he was aware that one Danny Hall, an 2 Outlaws member he had known for 25 years, had been incarcerated on 3 several occasions at the Webster CI where Kight was a correctional 4 officer. Kight said of Hall, "[h]e never asked me to do any favors 5 or anything illegal for him while I performed my job." 6 Vincenzo, who said he had never been a member of the 7 Outlaws, stated that he did associate with some members of the Club 8 and had attended OMC functions in Waterbury and in Brockton, 9 Massachusetts. He had no knowledge of any illegal activity of the 10 Outlaws and did not know any members of the Outlaws who had 11 previously been incarcerated. Vincenzo acknowledged that, in a 12 videotaped surveillance of the Outlaws party in Waterbury on July 13 12, 2003, he was seen wearing an Outlaws Support T-shirt. 14 Vincenzo stated that he had "heard that there might be 15 some type of issue with guys that ride in motorcycle clubs," and he 16 had sought official advice as to whether affiliation with the 17 Outlaws would threaten his employment with DOC. He stated that, 18 while attending a retirement party in the summer of 2003, he had 19 asked a DOC captain to make inquiry of DOC's director of security. 20 Vincenzo said he was told that the director believed there would be 21 no problem if Vincenzo himself was not committing a crime. Vincenzo 22 stated that he received essentially the same advice from a local 23 chief of police. 24 Scappini, who stated that he had never been a member or a 25 prospect of the Outlaws or associated with the Club, stated that he 26 had attended parties and functions with the Outlaws. He had seen 27 Kight, with whom he worked at the Webster CI, at some of the Outlaws -11- 1 functions. Scappini stated that he was "not aware of" and had not 2 "seen any illegal activity by any member of the Outlaws Motorcycle 3 Club." He said, however, that he had recognized Danny Hall at 4 Outlaws functions and was aware that Hall had been an inmate at the 5 Webster CI. Scappini stated that Hall "never asked me to do 6 anything illegal while he was incarcerated." 7 2. The DOC 2003 Report 8 Following these interviews and the gathering of additional 9 information from federal, State, and local law enforcement agencies, 10 the Security Division sent Lantz the DOC 2003 Report. The report 11 recounted, inter alia, law enforcement experiences with the Outlaws, 12 from both federal and local perspectives, as summarized in Parts 13 I.A.1. and I.A.2. above, including the NDIC Report's description of 14 the Outlaws' drug trafficking, violence, and other criminal 15 activity. 16 The DOC Report also summarized the NDIC Report's 17 description of the Outlaws membership requirements, in part, as 18 follows: 19 Outlaws members must be male, at least 21 years 20 old and own an[] American-made motorcycle with at 21 least a 1,000 cc engine. To be accepted as a 22 member, an individual must begin as an associate or 23 "hangaround" and must perform some service for the 24 chapter. If chapter officers determine that the 25 hangaround has membership potential, he becomes a 26 "prospect", and when he is deemed ready for formal 27 consideration, he become[s] a "probate". For a 28 period of at least 6 months, the probate officially 29 is evaluated for membership and may be asked to 30 perform some illegal activity to prove his loyalty. 31 To obtain full membership the probate must attend 32 one national event and receive the unanimous vote of -12- 1 the chapter. . . . A member in good standing can 2 leave the club or change chapters at any time after 3 1 year. However, a member must have at least 10 4 years with the club before he is permitted to keep 5 OMC emblems and Patches. . . . 6 Members wear black leather jackets. The club 7 patches, known as colors, are placed on the front 8 and back of the jackets. Outlaws patches are 9 usually black and white lettering. The skull and 10 crossed pistons logo is outline[d] in red and worn 11 on the back of the jacket. OMC members maintain 12 that the skull's glaring red eyes protect the wearer 13 and "watch out for trouble from behind." Above the 14 logo is a top rocker patch with the name Outlaws, 15 below the logo is a bottom rocker that designates 16 the chapter's location. A triangular patch is worn 17 on the left front shoulder with the letters AOA 18 standing for American Outlaws Association 19 surrounding a hand with the middle finger 20 extended. . . . On the other shoulder is worn a 21 triangular 1 % patch. The 1 % refers to a statement 22 made by the former president of the American 23 Motorcycle Association that 99 percent of the 24 motorcycling public are honest, law abiding citizens 25 and that only 1 percent are trouble makers. A patch 26 with the letters GFOD, standing for the Outlaws' 27 motto "God Forgives, Outlaws Don't" also is worn on 28 the front of the jacket. 29 Associates and prospects wear only front 30 patches to identify their status. Probates wear 31 upper Probationary and lower Outlaws rocker patches 32 on their backs. Female associates wear the 33 traditional OMC back patch with "Property of" on the 34 top rocker and the name of the owner on the bottom 35 rocker. . . . Colors are held in the highest 36 esteem. A member who loses his colors is fined $500 37 and demoted to probate status. 38 (DOC 2003 Report at 4 (emphases added).) 39 The DOC 2003 Report summarized SD's September 2003 40 interviews of plaintiffs, see Part I.B.1. above, and stated that 41 there were discrepancies between some of the interview statements 42 and the facts found in DOC's investigation. In particular, the 43 statements by Piscottano and Kight that they had "gotten out [of the 44 Outlaws] early in 2003" were questioned, given that during the -13- 1 period after they said they had withdrawn, Piscottano and Kight were 2 "positively identified and admitted to being in attendance during 3 one or several of the functions that were sponsored by the Outlaws 4 Motorcycle Club." (DOC 2003 Report at 14.) Kight, during that 5 period, was observed wearing Outlaws colors despite having resigned 6 after being a member for less than a year and despite the Outlaws 7 bylaw forbidding post-resignation retention of colors except by 8 those who have been members for at least 10 years. One such 9 observation was made by Irizarry, who conducted surveillances of the 10 Outlaws and was the author of the DOC 2003 Report: 11 On September 5, 2003 while out with friends at 12 Carmine's Café in Waterbury, Major Irizarry observed 13 several individuals on motorcycles arrive outside of 14 the Café. All of the individuals we[re] wearing 15 leather jackets or vest[s] identifying them with the 16 Outlaws Motorcycle Club. Major Irizarry positively 17 identified Officer James Kight as one of the 18 individuals that was with the group. Officer Kight 19 was observed wearing a leather jacket with the 20 Outlaws rocker on the back. 21 (Id. at 13 (emphasis added); see also id. at 15 ("Kight stated 22 during his interview that he was riding with members of the Outlaws 23 on the evening of September 5, 2003, but was not wearing any colors, 24 since he was no longer a member. But I clearly observed him wearing 25 his colors upon arriving and parking in front of the Café.").) 26 The DOC Report also stated that during one or more of the 27 Outlaws events at which Piscottano, Kight, Vincenzo, and Scappini 28 were seen, several known felons were also observed. (See id. at 29 14.) At a May 2003 Outlaws event, several of the "known felons 30 . . . were wearing full patched Outlaw jackets." (Id. at 12.) 31 Attending a later Outlaws event was a felon who had just been 32 released from prison in July 2003. (See id. at 14; see also id. at -14- 1 11 (Hall, whom Kight described as having been incarcerated on 2 several occasions at the prison to which Kight was assigned, had 3 been released in July 2003).) The report stated that it was a 4 matter of "clear concern" that 5 correctional staff [are] associating with known 6 felons and other members of this organization. The 7 information in this report identifying the criminal 8 involvement, producing and distributing of 9 methampheta[m]ine and other narcotics indicates that 10 the Outlaws Motorcycle Club are [sic] becoming a 11 great threat to the general public and law 12 enforcement agencies. 13 (Id. at 15.) The report found that by associating with the Outlaws, 14 the correctional officers in question had, inter alia, (1) 15 "jeopardize[d] the security of the unit, health, safety, or welfare 16 of the public, staff or inmates," (2) "[e]ngage[d] in conduct that 17 constitutes, or gives rise to, the appearance of a conflict of 18 interest," and (3) "[e]ngage[d] in unprofessional . . . behavior 19 . . . that could . . . reflect negatively on the Department of 20 Correction." (Id. at 15-18.) The report concluded that the 21 officers were therefore "in clear violation" of Directive 2.17. 22 (Id. at 15.) 23 The DOC 2003 Report also noted that Directive 2.17 24 requires employees to "[c]ooperate fully and truthfully in any 25 inquiry or investigation conducted by the Department of Correction 26 and any other law enforcement or regulatory agency." (Id.) The DOC 27 Report concluded, inter alia, that "[i]t has been determined that 28 . . . Piscottano[] and Kight were not truthful during the 29 investigation, since they . . . claim to have gotten out of the 30 Outlaws early in 2003, but continue to attend functions hosted by 31 the Outlaws." (Id.) -15- 1 C. The Individual Proceedings and the Imposition of Discipline 2 In late 2003, Lantz ordered that separate proceedings be 3 initiated against Piscottano, Kight, Vincenzo, and Scappini, as well 4 as Sabettini; that each officer be placed on paid administrative 5 leave pending conclusion of his proceeding; and that each be given 6 a copy of the DOC 2003 Report and be afforded an opportunity at a 7 Loudermill hearing to present any mitigating evidence and to dispute 8 the allegations of the DOC Report. 9 Loudermill hearings were conducted and were followed by 10 Security Division investigations into the evidence presented by the 11 officers at those hearings and into each officer's activities with 12 the Outlaws subsequent to his SD interview in September 2003. In 13 February 2004, an individual report ("SD 2004 Report") was prepared 14 with respect to each of the plaintiffs. Each report reiterated the 15 historical perspective of the Outlaws set out in the DOC 2003 Report 16 and noted that 17 [t]hough the OMC has only beg[u]n to become 18 established in New England within the past 5 years, 19 law enforcement sources have stated that there have 20 already been arrests and violent altercations 21 between the OMC and [the Hells Angels]. Though 22 there are several on-going investigations concerning 23 the OMC in New England, law enforcement sources were 24 unable to provide specifics [so] as to not 25 jeopardize the integrity of their cases. 26 (E.g., SD 2004 Report on Piscottano at 3-4.) Each report added the 27 observation that 28 [a]s with other chapters of the OMC, law enforcement 29 sources expect the newly founded New England 30 chapters to follow suit with the criminal activity 31 of older established chapters, which has been made -16- 1 apparent by information received from current 2 on-going investigations, 3 (e.g., id. at 6), citing as "[a]n example of the criminal 4 progression of the newly formed New England chapters" the February 5 2002 arrests of 23 heavily armed Outlaws members who were preparing 6 for a fight with the Hells Angels in Revere, Massachusetts (e.g., 7 id.). 8 Each report proceeded to describe the officer's Loudermill 9 hearing statements and the evidence turned up in SD's follow-up 10 investigation. As described below, although the September 2003 11 interviews and the DOC 2003 Report, which had been given to the 12 plaintiffs, had put all of them on notice that the Outlaws was 13 considered by federal, State, and local law enforcement agencies to 14 be engaged in criminal activity, and that DOC was concerned about 15 plaintiffs' association with the Outlaws, the individual reports 16 found that Kight and Piscottano had continued to wear Outlaws colors 17 and to involve themselves in Outlaws-related activities. 18 1. Kight 19 At his Loudermill hearing, Kight took the position, inter 20 alia, that he had not (as described in the DOC 2003 Report at 13) 21 been wearing an Outlaws rocker patch on his jacket at Carmine's Café 22 on September 5, 2003, and he stated that there had been another DOC 23 correctional officer at that café at the time who would so testify. 24 In the Security Division's post-Loudermill-hearing interview, Kight 25 identified his witness as Lawrence Andrews, a correctional officer 26 at the Webster CI where Kight was assigned. 27 SD then interviewed Andrews. Andrews said he had been -17- 1 present in Carmine's Café on one occasion when Kight and a woman 2 came into the café, and that Kight had not been wearing Outlaws 3 colors. However, Andrews could not remember the date of that 4 occasion and could not say that it was September 5. (See SD 2004 5 Report on Kight at 6.) On the occasion he recalled, Kight and the 6 woman had come in alone (see id.); Kight, however, in his September 7 2003 interview, had stated that he was with members of the Outlaws 8 on the evening of September 5 (see DOC 2003 Report at 15). The 2004 9 report noted that SD investigator Irizarry himself had observed 10 Kight arrive at that café on September 5, with several other 11 individuals wearing Outlaws colors, and had observed Kight wearing 12 a black leather jacket with the Outlaws rocker on the back. (SD 13 2004 Report on Kight at 6-7.) 14 The report also noted that although Kight stated he had 15 resigned from the Outlaws in July, 16 he has admitted wearing colors during an OMC 17 Christmas Party on December 20, 2003. When asked if 18 the colors were his, Officer Kight stated that the 19 colors were brought down for him to wear out of 20 respect by members of the OMC. Officer Kight 21 admitted wearing an OMC insignia belt while at the 22 Christmas Party. 23 (Id. at 7.) 24 The report on Kight also stated that SD had learned that 25 Kight and Piscottano were involved in a physical altercation at 26 Chaser's Café in Bristol, Connecticut, on October 25, 2003. An 27 employee of that café informed investigators that Kight was injured 28 when a member of the Crossroads Motorcycle Club hit Kight in the 29 face with a beer mug, and that gunshots were fired. Kight was 30 dragged out of the café by one of the Outlaws members. The café -18- 1 employee stated that Kight and Piscottano, as well as certain other 2 full-patch members of the Outlaws whom the employee identified by 3 name, were all wearing Outlaws colors. 4 After the fight, Kight was hospitalized and underwent 5 surgery for the injuries to his face (a broken jaw and a broken 6 nose, according to Kight's testimony at the preliminary injunction 7 hearing). Kight admitted that he had been at Chaser's Café on the 8 night of October 25 and had been knocked unconscious; but he said he 9 had no idea who struck him, and he maintained that his injuries were 10 in fact caused by his slipping and falling in his bathtub while 11 taking a shower. (See SD 2004 Report on Kight at 7-9.) According 12 to the State Police, Kight's "injuries were inconsistent with a fall 13 and were consistent with someone involved in a physical 14 altercation." (Id. at 7.) 15 The SD report found, inter alia, that although Kight 16 contended that he had not engaged in conduct that would be 17 considered a conflict of interest, 18 he continues to associate himself with members of 19 the OMC by attending functions such as the Christmas 20 Party on December 10 [sic], 2003[, e]ven after being 21 placed on Administrative Leave by the DoC for his 22 association with a known criminal entity, which is 23 currently being investigated by State and local law 24 enforcement for criminal/illegal activities. 25 (SD 2004 Report on Kight at 9.) The report concluded that Kight had 26 violated Directive 2.17 by, inter alia, engaging in unprofessional 27 behavior that could reflect negatively on DOC and give rise to the 28 appearance of a conflict of interest, and by failing to cooperate 29 fully and giving false testimony in the DOC investigation. (Id. at 30 10.) -19- 1 2. Piscottano 2 The Security Division report on Piscottano stated that SD 3 had conducted a post-Loudermill-hearing interview of Piscottano, 4 seeking clarification of his proffered mitigation, but that 5 Piscottano failed to provide detailed information in response to 6 most of SD's questions. He said he had no knowledge about the 7 Outlaws national organization and no recollection of the specific 8 period when he was an Outlaws member or when he attended Outlaws 9 functions. (See SD 2004 Report on Piscottano at 6 ("Piscottano 10 failed to provide this office with specific time frames concerning 11 his membership and/or attendance at OMC functions, stating that he 12 was unsure, couldn't recall or would have to guess.").) 13 The report noted that Piscottano placed his resignation 14 from the Outlaws in the spring of 2003, but that 15 he stated that he still attended OMC functions 16 including parties at the Waterbury OMC clubhouse and 17 Lobsterfest in Brockton, Massachusetts (party 18 sponsored by the Brockton OMC). Officer Piscottano 19 also stated that most recently he attended a 20 Christmas party at the Waterbury OMC clubhouse on 21 December 20, 2003 (the party followed Officer 22 Piscottano's Loudermill and being advised that his 23 involvement with the organization may result in his 24 dismissal from state service). 25 (Id.) SD had learned of Piscottano's presence at the Outlaws 26 Christmas party because he had been seen there by members of the 27 State Police who were serving a search warrant at the Outlaws 28 clubhouse (although they had "extreme difficulty entering the 29 building, as the interior walls of the clubhouse were covered with 30 sheet metal and the door was steel reinforced"), seeking illegal 31 weapons believed to be in the possession of a known Outlaws member 32 who was attending the event. (Id.) In his SD interview, Piscottano -20- 1 was critical of the police, stating "I couldn't believe they were 2 doing this at a Christmas party." (Transcript of December 22, 2003 3 SD Interview of Piscottano, at 12.) 4 Piscottano was also questioned about the October 25, 2003 5 incident at Chaser's Café at which Kight was injured (see Part 6 I.C.1. above). Piscottano denied being at that café on that date; 7 said he was unsure whether he had ever been there; and said he did 8 not know, offhand, where it was located. The report stated, 9 however, that the café "employee was shown several pictures of OMC 10 members and clearly identified Officer Piscottano and Officer Kight 11 as being involved in the altercation while wearing their OMC 12 colors." (SD 2004 Report on Piscottano at 7.) 13 The report noted that Kight had been admitted to Waterbury 14 Hospital on the night of October 25 with severe facial injuries that 15 required surgery and that Piscottano admitted having visited Kight 16 in the hospital. However, despite that visit, Piscottano stated 17 that he did not know what had precipitated Kight's admittance to the 18 hospital, "nor did he inquire." (Id.) 19 The SD report found that 20 [u]pon review of Officer Piscottano's 21 Loudermill reply and questioning to clarify his 22 alleged mitigation, this office has concluded that 23 Officer Piscottano continues to be actively involved 24 with the Outlaw Motorcycle Club and was less than 25 truthful in regards to his membership. Though 26 Officer Piscottano alleged that he is no longer a 27 member of the OMC, this office has not been 28 presented with any mitigating evidence that would 29 support this claim. . . . 30 This office has also determined that Officer 31 Piscottano was less than truthful in regards to the 32 incident at Chaser's Café on October 25, 2003, where 33 Officer Kight was struck in the face and knocked 34 unconscious by members of the Crossroads Motorcycle -21- 1 Club and James Gang (motorcycle club). Officer 2 Piscottano was identified (via photograph) by an 3 employee of the café as being present during the 4 melee, though he stated that he was not. 5 (Id. at 7.) The report also found it less than credible that 6 Piscottano would visit Kight in the hospital following the surgery 7 on Kight's nose and jaw, and neither know nor ask what had happened. 8 (See id. at 7-8.) 9 The SD report concluded that although members of the 10 Waterbury chapter of the Outlaws had not been charged with felonious 11 activity, it "is currently under investigation by several Federal, 12 State and local law enforcement entities for just such activity," 13 and that "[i]t should be noted that Officer Piscottano continues to 14 attend OMC events and socialize with the organization's members, 15 even after being advised that the agency was investigating his 16 involvement with the organization." (SD 2004 Report on Piscottano 17 at 8.) The report concluded that Piscottano had violated Directive 18 2.17 by engaging in unprofessional behavior that could reflect 19 negatively on DOC and give rise to the appearance of a conflict of 20 interest, as well as by failing to cooperate fully in the DOC 21 investigation and giving false testimony. (See id.) 22 3. Vincenzo 23 The post-Loudermill hearing report on Vincenzo described 24 an interview in which Vincenzo reiterated the statements he had made 25 during his September 2003 interview that, inter alia, he had 26 inquired of a DOC captain and, indirectly, the DOC director of 27 security as to the propriety of riding with motorcycle clubs and had 28 been informed that it was not inappropriate so long as he was not -22- 1 committing any crimes. SD investigators spoke with the DOC captain 2 of whom Vincenzo had inquired and with the security director; both 3 essentially substantiated Vincenzo's account. (SD 2004 Report on 4 Vincenzo at 7-8.) 5 Vincenzo also stated that if any DOC official had informed 6 him that it was inappropriate to ride around with felons and had 7 pointed out individuals who were felons, he "would have been gone." 8 (Id. at 7.) Vincenzo stated that although he had attended Outlaws 9 events in the past, he had not done so since September 2003. The 10 report indicated that SD had received no information indicating 11 Vincenzo's presence at any Outlaws event since that time. (See id. 12 at 8.) 13 The report concluded that Vincenzo's prior association 14 with the Outlaws constituted unprofessional behavior that could 15 reflect negatively on DOC and give rise to the appearance of a 16 conflict of interest. (See id. at 8-9.) 17 4. Scappini 18 In SD's post-Loudermill hearing interview of Scappini, 19 Scappini essentially repeated the statements he had made in his SD 20 interview in September 2003, i.e., that he had never been an 21 associate, prospect, or member of the Outlaws, although he had 22 attended several Outlaws outings in prior years. (SD 2004 Report on 23 Scappini at 7.) The report stated that SD had received no 24 information indicating Scappini's presence at any Outlaws event 25 after May 24, 2003. (See id.) -23- 1 The report concluded that Scappini's prior association 2 with the Outlaws constituted unprofessional behavior that could 3 reflect negatively on DOC and give rise to the appearance of a 4 conflict of interest. (See id. at 7-8.) 5 5. The April 2004 Dismissals and Counseling Letters 6 Murphy, as deputy commissioner in charge of operations, 7 reviewed the SD reports on the individual officers and gave Lantz 8 his view that it was inadvisable to employ correctional officers who 9 were affiliated with the Outlaws. (See Memorandum from Murphy to 10 Lantz dated March 23, 2004 ("Murphy Mem.").) Murphy testified that 11 after receiving the NDIC Report, he had sought and received 12 corroborating information from the State Police, from law 13 enforcement agencies in Massachusetts and New Hampshire, and from 14 federal agencies including the BATF and the United States Drug 15 Enforcement Administration. (See Tr. 231-32.) And "the more 16 information [he] got, the more [he] became concerned." (Id. at 17 236.) 18 DOC was aware of at least two members of the Outlaws 19 incarcerated in DOC prisons and of members of the Hells Angels and 20 other motorcycle clubs incarcerated at several DOC prisons. Murphy 21 testified that DOC had experienced gang-rivalry incidents of inmate 22 violence in the past between members of gangs other than the Outlaws 23 and the Hells Angels, including one incident in which an inmate was 24 beaten to death with a putter and another in which an inmate was 25 firebombed to death. (See Tr. 235, 258.) Although there had been 26 no incidents in DOC-run prisons involving the Outlaws, and the -24- 1 Outlaws was not on DOC's own list of organizations that were known 2 to pose security risks (see id. at 259-60, 276-77), DOC had been 3 informed by the Federal Bureau of Prisons that the Outlaws 4 Motorcycle Club is listed as a safety threat group within the 5 federal prison system (see, e.g., id. at 293). 6 In his memorandum to Lantz, Murphy noted that the 7 historical involvement of the OMC "around the country" in "illegal, 8 illicit, violent, and dangerous activities" was "substantiated" 9 (Murphy Mem. at 1), and that law enforcement surveillance of the 10 Connecticut chapter of the Outlaws had made it "clearly evident that 11 the OMC membership involves several convicted felons" (id. at 2). 12 Murphy also noted that "gang affiliation and loyalties to the gang 13 do not cease with incarceration" and that a correctional officer 14 affiliated with the Outlaws, supervising inmates belonging to a 15 different gang, "could be subjected to criticism by inmate rival 16 gang members, alleging inappropriate treatment based on rival status 17 of the gangs." (Id.) Such an officer could also be subjected to 18 "retaliation by inmates." (Id.) For example, a State Police 19 ("CSP") task force member had reported on his recent conversation 20 with a leader of the Hells Angels in which 21 the Hells Angels leader notified the CSP member of 22 "cops" being with the Outlaws; referring to the 23 correctional officers. The Hells Angels leader 24 spoke of the feud with OMC, and warned that the 25 officers were in jeopardy due to their membership 26 with OMC. 27 (Id.) 28 Murphy concluded that the association of DOC correctional 29 officers with the Outlaws "severely jeopardizes the security of the 30 [prison] facilities and protection of the public" and "could also -25- 1 severely impact the integrity of the agency and its security." (Id. 2 at 2-3.) Murphy concluded that 3 [t]he staff members who do not appear to be members 4 [of the Outlaws] should be warned that continued 5 involvement with this gang may result in termination 6 from state service. Those positively identified as 7 members should be dismissed from state service. 8 (Id. at 3.) 9 Lantz agreed with Murphy's assessments and concerns. (See 10 generally Tr. 326-27.) At the preliminary injunction hearing, she 11 testified that DOC works closely with other law enforcement agencies 12 and has staff members participate in task forces on gang activity. 13 (See id. at 310.) Lantz testified that the concerns for possible 14 conflicts of interest, coupled with the findings that Piscottano and 15 Kight had been untruthful in their interviews with SD investigators, 16 led her to believe that there "was a breach of integrity, certainly 17 unprofessional," that "negatively reflected on the agency." (Id. at 18 327.) Asked to explain why she believed Department operations could 19 be negatively affected by a correctional officer's untruthfulness, 20 Lantz stated, 21 we have a finding of untruthfulness and if no action 22 is taken and they're allowed to go back to work or 23 allowed to carry out their duties, anything else 24 they might do in the performance of their duties 25 could make the agency quite vulnerable by the fact 26 that the agency has already found them untruthful. 27 (Id. at 332 (emphasis added).) 28 Lantz followed Murphy's recommendations. In April 2004, 29 Kight and Piscottano were informed, by the wardens of the prisons to 30 which they were respectively assigned, that they were being 31 dismissed, effective May 6, 2004, for violating Directive 2.17. The 32 letter to Kight stated, in pertinent part, as follows: -26- 1 This letter serves to inform you that you are 2 being dismissed from State Service for just cause as 3 evidenced by your violation of Administrative 4 Directive 2.17. 5 Specifically, based upon a Security Division 6 investigation into your conduct, it was determined 7 that you were less than truthful when questioned 8 about your association with the Outlaw[s] Motorcycle 9 Club. Your failure to be truthful jeopardizes the 10 safety and security of yourself, your co-workers and 11 the inmates, which cannot be tolerated or condoned. 12 (Letter from Warden James E. Dzurenda to Kight dated April 22, 13 2004.) Piscottano's termination letter was essentially the same. 14 (See Letter from Warden Wayne T. Choinski to Piscottano dated April 15 21, 2004.) 16 Vincenzo and Scappini were not dismissed; they were issued 17 "Formal Counseling" letters for engaging in unprofessional conduct 18 in violation of Directive 2.17. Each letter stated that "a Security 19 Division investigation substantiated that you engaged in activities 20 that negatively reflected on the Department of Correction." (E.g., 21 Letter from Warden James E. Dzurenda to Scappini dated April 22, 22 2004.) The counseling letters stated that "[t]his type of conduct 23 will not be tolerated," and that "[a]ny recurrence of this behavior 24 will result in more severe disciplinary action being taken against 25 you up to and including dismissal." (E.g., id.) 26 6. The November 2004 Discharge of Vincenzo 27 In July 2004, Lantz received a letter from the president 28 of the prison employees' union asking whether Vincenzo would violate 29 any Department regulation if he attended a fund-raising event to be 30 co-sponsored by the Outlaws at the American Veterans ("AmVets") hall 31 in Enfield, Connecticut, from noon to 6 p.m. on July 11, 2004. -27- 1 Lantz responded that if Vincenzo attended the event, he would be 2 violating Directive 2.17. Vincenzo received a copy of Lantz's 3 response prior to the July 11 event. 4 Lantz thereafter received information that Vincenzo had 5 proceeded to attend the July 11 Outlaws event; she instructed SD to 6 investigate. SD obtained and reviewed videotapes that had been made 7 during surveillance of the event by the Enfield Police Department. 8 In a memorandum dated August 13, 2004 ("SD August 2004 Report on 9 Vincenzo"), SD reported that on the police surveillance tape 10 covering the segment of the afternoon of July 11 from 1:53 p.m. to 11 4 p.m., Vincenzo was seen arriving at the AmVets hall at 12 approximately 3:43 p.m. (See SD August 2004 Report on Vincenzo at 13 2.) He parked his motorcycle, greeted and hugged members of the 14 Outlaws, and remained in the company of Outlaws members until those 15 attending the party departed at approximately 6:10 p.m. "Vincenzo 16 [wa]s seen riding away with the Outlaws members," and "at th[at] 17 time he [wa]s observed wearing a black short sleeve tee-shirt which 18 appeared to be a 'Support' (Outlaws MC) tee-shirt." (Id.) 19 After reviewing the videotape, SD interviewed Vincenzo. 20 Although Vincenzo maintained that he did not "attend" the event 21 (Transcript of July 26, 2004 SD Interview of Vincenzo, at third 22 unnumbered page), he concededly went to the AmVets hall on July 11, 23 2004, before the 6 p.m. scheduled conclusion of the event (see id. 24 at second unnumbered page ("I don't even know what time I went down 25 there. . . . I think I went down there about five, five thirty 26 somewhere around there.")). Vincenzo acknowledged that upon his 27 arrival he hugged and shook hands with members of the Club, that -28- 1 while there he consumed a few beers with Outlaws members (see id. at 2 second-third unnumbered pages), and that before he left he donned an 3 Outlaws "support shirt" that had been brought to him (id. at fourth 4 unnumbered page). 5 Lantz ordered that Vincenzo be given a new Loudermill 6 hearing to determine whether his conduct on July 11, 2004, warranted 7 discharge or other discipline. Following the new Loudermill 8 hearing, Lantz determined that Vincenzo should be dismissed for 9 violating Directive 2.17. He was discharged on November 19, 2004. 10 D. The Present Action and the Decision of the District Court 11 Immediately following the April 2004 dismissals of 12 Piscottano and Kight and the counseling letters to Vincenzo and 13 Scappini, those four officers, along with Sabettini who also had 14 been discharged, commenced the present suit under 42 U.S.C. § 1983 15 against Lantz, Murphy, and the wardens who had signed the discharge 16 and counseling letters, asserting claims that those actions 17 violated, inter alia, plaintiffs' First Amendment rights. 18 Plaintiffs moved, unsuccessfully, for a preliminary injunction 19 requiring rescission of the disciplinary actions. See Piscottano I, 20 317 F.Supp.2d at 99-102. 21 Following the denial of the preliminary injunction motion, 22 several amended complaints were filed, which, inter alia, omitted 23 Sabettini as a plaintiff and omitted the wardens as defendants. To 24 the extent pertinent to this appeal, the third (final) amended 25 complaint ("Complaint"), served in November 2004, alleged that 26 Directive 2.17, in "prohibit[ing] . . . [e]ngage[ment] in -29- 1 unprofessional . . . behavior, both on and off duty, that could in 2 any manner reflect negatively on the Department," is 3 "unconstitutional as applied in this case, in that it violates the 4 First Amendment because it is . . . void for vagueness" (Complaint 5 ¶¶ 26, 27), and that defendants' imposition of discipline on 6 plaintiffs (including the then-recent discharge of Vincenzo for his 7 July 11, 2004 violation of Directive 2.17) violated their rights to 8 freedom of association (see id. ¶¶ 25, 28). 9 Following a period of discovery, both sides moved for 10 summary judgment. Defendants sought summary dismissal of the First 11 Amendment claims, arguing principally (1) that plaintiffs' 12 association with the Outlaws did not constitute speech on a matter 13 of public concern, as required by Connick v. Myers, 461 U.S. 138 14 (1983), and (2) that plaintiffs' interest in associating with the 15 Outlaws is, in any event, outweighed by the State's interest in, 16 inter alia, maintaining safe prison facilities, and hence is not 17 protected by the First Amendment. They argued that Directive 2.17 18 is not unduly vague as applied to plaintiffs' association with the 19 Outlaws. 20 Plaintiffs opposed defendants' motion, arguing principally 21 (a) that the Connick public-concern requirement should not be 22 applied to claims of freedom of association or to an employee's off- 23 duty speech that does not relate to his employment, and (b) that 24 Directive 2.17 is impermissibly vague as applied to plaintiffs 25 because it has no objective content setting forth standards or 26 giving fair notice as to what conduct is proscribed. 27 Plaintiffs also cross-moved for summary judgment in their favor. In -30- 1 addition to the arguments made in opposition to defendants' motion 2 for summary judgment, plaintiffs argued that they were entitled to 3 judgment on the void-for-vagueness claim because they had no reason 4 to believe that the Connecticut chapter of the Outlaws was involved 5 in any criminal activity and they had been led to believe by their 6 superiors at DOC that so long as plaintiffs themselves were not 7 involved in criminal activity, DOC did not disapprove of their 8 association with the Outlaws. 9 In a Memorandum of Decision dated June 9, 2005, see 10 Piscottano v. Murphy, No. 3:04CV682, 2005 WL 1424394 (D. Conn. June 11 9, 2005) ("Piscottano II"), the district court granted defendants' 12 motion for summary judgment dismissing the Complaint and denied 13 plaintiffs' cross-motion. The court dismissed plaintiffs' 14 expressive association claims on the ground that plaintiffs had not 15 shown that their association with the Outlaws constituted speech on 16 a matter of public concern. See id. at *5-*6. The district court 17 noted that this Court in Cobb v. Pozzi, 363 F.3d 89 (2d Cir. 2004), 18 had stated that "'[w]e . . . join[]'" other circuits and "'hold that 19 a public employee bringing a First Amendment freedom of association 20 claim must persuade a court that the associational conduct at issue 21 touches on a matter of public concern.'" Piscottano II, 2005 WL 22 1424394, at *3 (quoting Cobb, 363 F.3d at 102). Although the Cobb 23 Court had then proceeded to assume, rather than to decide, that the 24 conduct before it in fact touched on a matter of public concern, the 25 district court concluded that the Cobb statement of principle was 26 intended as guidance to the district courts and should be followed, 27 see Piscottano II, 2005 WL 1424394, at *3. The district court -31- 1 reasoned, alternatively, that because the public-concern test is 2 applicable to speech, which is explicitly protected by the First 3 Amendment, and freedom of association is not mentioned in the 4 Amendment but is derivative of freedom of speech, it would be 5 anomalous to hold that a plaintiff could prevail on a freedom-of- 6 expressive-association claim upon making a lesser showing than that 7 required for proof of a violation of the right to freedom of speech 8 itself. See id. at *4. The court also concluded that plaintiffs 9 were not exempt from the public-concern test for their speech or 10 expressive associations during their off-duty hours. See id. at *6. 11 The court noted that, in response to a question at oral 12 argument, "[p]laintiffs' counsel conceded . . . that if Plaintiffs 13 are required to satisfy the public concern requirement, their First 14 Amendment claim must fail . . . ." Id. at *2. The court 15 accordingly dismissed plaintiffs' expressive association claims. 16 As to plaintiffs' intimate association claims, the 17 district court noted, as set forth more fully in Part III below, 18 that in addition to the undisputed fact that "many of the Outlaws' 19 activities and events--such as motorcycle rides, cookouts and 20 parties--are freely open to non-members," it was "apparent that [the 21 Outlaws] is not a small group" and that it also is not "a 22 particularly selective organization." Id. at *7. The district 23 court thus concluded that association with the Outlaws "falls 24 outside of the range of intimate associations that are protected by 25 the First Amendment." Id. at *8. 26 As to plaintiffs' due process challenge to Directive 2.17, 27 the district court concluded that, even viewing the counseling -32- 1 letters as discipline and viewing plaintiffs as having been 2 disciplined because of their association with the Outlaws, and not 3 because of any untruthfulness, Directive 2.17 is not 4 unconstitutionally vague as applied to the Plaintiffs because its 5 terms "amply encompass[] the conduct with which Plaintiffs, by their 6 own characterization, were charged--that is, associating with a 7 group that Defendants understood to be 'a criminal enterprise,'" id. 8 at *11 (quoting Plaintiffs' Memorandum of Law in Opposition to 9 Defendants' Motion for Summary Judgment and in Support of 10 Plaintiffs' Cross-Motion for Summary Judgment ("Plaintiffs' Summary 11 Judgment Memorandum") at 48). 12 Addressing plaintiffs' assertion that they did not know 13 the Outlaws was a criminal organization, the district court pointed 14 out that it was an "undisputed fact that in November 2003 each 15 Plaintiff received a copy of the DOC's report outlining numerous 16 instances of criminal conduct by Outlaws members and officials." 17 Id. at *12. The court also noted that Kight and Piscottano had 18 "continued to attend Outlaws events even after being placed on 19 administrative leave pending DOC's full investigation of their 20 association with the Outlaws," id., and that "Vincenzo also 21 continued to attend the Outlaws' activities even after being told 22 expressly that attending Outlaws events would result in 23 termination," id. The district court concluded that 24 [t]here can be no serious dispute that a reasonable 25 corrections officer would recognize that a 26 regulation prohibiting him from "[e]ngaging in 27 unprofessional or illegal behavior--on or off duty-- 28 that could negatively reflect on the department" 29 would bar him from associating with a group that has 30 been identified, at least at the national level, as 31 having been involved in criminal and gang-related -33- 1 activities. 2 Id. (quoting DOC Employee Handbook). 3 Finally, the court rejected the claims of Piscottano and 4 Vincenzo that Directive 2.17 is impermissibly vague because 5 supervisors had misled them to believe that the directive did not 6 prohibit their association with the Outlaws. Id. at *13. Citing 7 Cox v. Louisiana, 379 U.S. 559 (1965), the court stated that 8 allegations of even official misinformation do not "render an 9 otherwise constitutional regulation void for vagueness" where the 10 party's conduct is clearly within the scope of the regulation. 11 Piscottano II, 2005 WL 1424394, at *13. The court noted that 12 Piscottano and Vincenzo had not asserted any claim of estoppel. See 13 id. 14 Judgment was entered dismissing the Complaint in its 15 entirety. On this appeal, plaintiffs pursue their expressive 16 association, intimate association, and void-for-vagueness claims. 17 II. FREEDOM OF EXPRESSIVE ASSOCIATION 18 In challenging the dismissal of their expressive 19 association claims, plaintiffs contend principally that the district 20 court erred (a) in ruling that they were required to show that their 21 expressive conduct was on a matter of public concern, and (b) in 22 failing to rule that their off-duty association with the Outlaws was 23 unrelated to their employment and hence was protected by the First 24 Amendment. For the reasons that follow, we affirm the dismissal of -34- 1 these claims, although our analysis differs from that of the 2 district court. 3 A. The Applicable Legal Principles 4 The First Amendment provides that "Congress shall make no 5 law respecting an establishment of religion, or prohibiting the free 6 exercise thereof; or abridging the freedom of speech, or of the 7 press; or the right of the people peaceably to assemble, and to 8 petition the Government for a redress of grievances." U.S. Const. 9 amend. I. Although freedom of expressive "association is not 10 explicitly set out in the Amendment, it has long been held to be 11 implicit in the freedoms of speech, assembly, and petition." Healy 12 v. James, 408 U.S. 169, 181 (1972). 13 The First Amendment, applicable to the states through the 14 Due Process Clause of the Fourteenth Amendment, see, e.g., Stromberg 15 v. California, 283 U.S. 359, 368 (1931), thus prohibits a state, as 16 sovereign, from abridging an individual's "'right to associate with 17 others in pursuit of a wide variety of political, social, economic, 18 educational, religious, and cultural ends,'" Boy Scouts of America 19 v. Dale, 530 U.S. 640, 647 (2000) (quoting Roberts v. United States 20 Jaycees, 468 U.S. 609, 622 (1984)), and from denying an individual 21 citizen "rights and privileges solely because of [his] association 22 with an unpopular organization," Healy, 408 U.S. at 186. "[G]uilt 23 by association alone, without [establishing] that an individual's 24 association poses the threat feared by the Government, is an 25 impermissible basis upon which to deny First Amendment rights." Id. 26 (internal quotation marks omitted). -35- 1 1. The State as Employer, and the Pickering Test 2 When acting as an employer, "the State has interests . . . 3 in regulating the speech of its employees that differ significantly 4 from those it possesses in connection with regulation of the speech 5 of the citizenry in general." Pickering v. Board of Education, 391 6 U.S. 563, 568 (1968). More than "[o]ne hundred years ago, the 7 [Supreme] Court noted the government's legitimate purpose in 8 'promot[ing] efficiency and integrity in the discharge of official 9 duties, and [in] maintain[ing] proper discipline in the public 10 service.'" Connick v. Myers, 461 U.S. 138, 150-51 (1983) (quoting 11 Ex parte Curtis, 106 U.S. 371, 373 (1882)). 12 "To this end, the Government, as an employer, must 13 have wide discretion and control over the management 14 of its personnel and internal affairs. This 15 includes the prerogative to remove employees whose 16 conduct hinders efficient operation and to do so 17 with dispatch. Prolonged retention of a disruptive 18 or otherwise unsatisfactory employee can adversely 19 affect discipline and morale in the work place, 20 foster disharmony, and ultimately impair the 21 efficiency of an office or agency." 22 Connick, 461 U.S. at 151 (quoting Arnett v. Kennedy, 416 U.S. 134, 23 168 (1974) (concurring opinion of Powell, J.)). 24 When someone who is paid a salary so that she will 25 contribute to an agency's effective operation begins 26 to do or say things that detract from the agency's 27 effective operation, the government employer must 28 have some power to restrain her. 29 Waters v. Churchill, 511 U.S. 661, 675 (1994) (plurality opinion). 30 In sum, "the government as employer indeed has far broader 31 powers than does the government as sovereign." Id. at 671. 32 The key to First Amendment analysis of 33 government employment decisions . . . is th[at t]he 34 government's interest in achieving its goals as 35 effectively and efficiently as possible is elevated 36 from a relatively subordinate interest when it acts -36- 1 as sovereign to a significant one when it acts as 2 employer. The government cannot restrict the speech 3 of the public at large just in the name of 4 efficiency. But where the government is employing 5 someone for the very purpose of effectively 6 achieving its goals, such restrictions may well be 7 appropriate. 8 Id. at 675. 9 This does not mean that public employees, merely by 10 accepting public employment, "relinquish the First Amendment rights 11 they would otherwise enjoy as citizens to comment on matters of 12 public interest in connection with the [government's] operation," 13 Pickering, 391 U.S. at 568, for "the First Amendment's primary aim 14 is the full protection of speech upon issues of public concern, as 15 well as the practical realities involved in the administration of a 16 government office," Connick, 461 U.S. at 154. Accordingly, 17 [t]he problem in any case is to arrive at a balance 18 between the interests of the [employee], as a 19 citizen, in commenting upon matters of public 20 concern and the interest of the State, as an 21 employer, in promoting the efficiency of the public 22 services it performs through its employees. 23 Pickering, 391 U.S. at 568. See also Garcetti v. Ceballos, 126 S. 24 Ct. 1951 (2006) (statements made by a public employee pursuant to 25 his official duties, rather than as a citizen, are not protected by 26 the First Amendment). 27 The Pickering test thus poses two questions (the first 28 being "implicit in Pickering," City of San Diego v. Roe, 543 U.S. 29 77, 82 (2004) ("Roe")): (1) whether the employee's speech as a 30 citizen was on a matter of public concern, and if so, (2) whether 31 the employer has shown that the employee's interest in expressing 32 himself on that matter is outweighed by injury that the speech could 33 cause to the employer's operations. See, e.g., Garcetti, 126 S. Ct. -37- 1 at 1958; Waters, 511 U.S. at 668 (plurality opinion); Connick, 461 2 U.S. at 142; Pickering, 391 U.S. at 568. 3 The issue of whether the subject of an employee's speech 4 or expressive conduct is a matter of public concern is a threshold 5 question. See, e.g., Roe, 543 U.S. at 84. If the employee "fails 6 th[is] threshold test[,] Pickering balancing does not come into 7 play." Id.; see, e.g., Connick, 461 U.S. at 146 (if the employee's 8 speech "cannot be fairly characterized as constituting speech on a 9 matter of public concern, it is unnecessary for us to scrutinize the 10 reasons for her discharge"). Thus, we ask first whether the 11 employee's expressive conduct was speech as a citizen on a matter of 12 public concern. "If the answer is yes, then the possibility of a 13 First Amendment claim arises." Garcetti, 126 S. Ct. at 1958. "If 14 the answer is no, the employee has no First Amendment cause of 15 action based on his or her employer's reaction to the speech." Id. 16 2. Public Concern 17 Because the meaning and application of constitutional 18 provisions are issues of law that must be determined by the court, 19 the question of whether an employee's expressive activity is speech 20 on a matter of public concern is an issue of law for the court. 21 See, e.g., Connick, 461 U.S. at 150 n.10. In considering a First 22 Amendment claim of deprivation of the right to free speech, "we are 23 compelled to examine for ourselves the statements in issue and the 24 circumstances under which they [were] made to see whether or not 25 they . . . are of a character which the principles of the First 26 Amendment, as adopted by the Due Process Clause of the Fourteenth -38- 1 Amendment, protect." Id. (internal quotation marks omitted); see, 2 e.g., id. at 148 n.7 ("The inquiry into the protected status of 3 speech is one of law, not fact."); Waters, 511 U.S. at 668 4 (plurality opinion) ("it is the court's task to apply the Connick 5 test to the facts"). 6 The question of what is a matter of public concern is not 7 amenable to a simple, definitive answer. Nonetheless, 8 Connick provides some guidance. It directs courts 9 to examine the "content, form, and context of a 10 given statement, as revealed by the whole record" in 11 assessing whether an employee's speech addresses a 12 matter of public concern. [461 U.S.] at 146-147. 13 In addition, it notes that the standard for 14 determining whether expression is of public concern 15 is the same standard used to determine whether a 16 common-law action for invasion of privacy is 17 present. Id., at 143, n. 5. That standard is 18 established by our decisions in Cox Broadcasting 19 Corp. v. Cohn, 420 U.S. 469 (1975), and Time, Inc. 20 v. Hill, 385 U.S. 374, 387-388 (1967). These cases 21 make clear that public concern is something that is 22 a subject of legitimate news interest; that is, a 23 subject of general interest and of value and concern 24 to the public at the time of publication. 25 Roe, 543 U.S. at 83-84 (emphasis added); see also Connick, 461 U.S. 26 at 146 (speech on a matter of public concern is speech "relating to 27 any matter of political, social, or other concern to the 28 community"). 29 3. Employer Justification for Restricting Employee Speech 30 If it is determined that the employee's expressive conduct 31 as a citizen involved a matter of public concern, the government 32 bears the burden of justifying its adverse employment action. See, 33 e.g., United States v. National Treasury Employees Union, 513 U.S. 34 454, 466 (1995) ("NTEU"). Justifications may include such -39- 1 considerations as maintaining efficiency, discipline, and integrity, 2 preventing disruption of operations, and avoiding having the 3 judgment and professionalism of the agency brought into serious 4 disrepute. See, e.g., Waters, 511 U.S. at 675 (plurality opinion). 5 Evidence that such harms or disruptions have in fact 6 occurred is not necessary. The employer need only make a reasonable 7 determination that the employee's speech creates the potential for 8 such harms. "[W]e do not see the necessity for an employer to allow 9 events to unfold to the extent that the disruption of the office and 10 the destruction of working relationships [are] manifest before 11 taking action." Connick, 461 U.S. at 152. 12 Further, "[w]hen close working relationships are essential 13 to fulfilling public responsibilities, a wide degree of deference to 14 the employer's judgment is appropriate." Id. at 151-52; see, e.g., 15 Waters, 511 U.S. at 673 (plurality opinion) ("government employers' 16 reasonable predictions of disruption, even when the speech involved 17 is on a matter of public concern" are "given substantial weight"); 18 id. ("we have consistently given greater deference to government 19 predictions of harm used to justify restriction of employee speech 20 than to predictions of harm used to justify restrictions [by the 21 government as sovereign] on the speech of the public at large"). 22 Such deference to the government's assessment of potential harms to 23 its operations is appropriate when the employer has conducted an 24 objectively reasonable inquiry into the facts--an inquiry that need 25 not be constrained by the rules of evidence, such as the rule 26 against hearsay, applicable in judicial proceedings--and has arrived 27 at a good faith conclusion as to those facts. See id. at 676-77 -40- 1 (plurality opinion). If the employer meets this test, it may, as a 2 matter of law, impose the discipline it deems reasonable, based on 3 the facts it has found, without incurring liability. See, e.g., id. 4 (plurality opinion); see also id. at 685 (concurring opinion of 5 Souter, J.) ("A majority of the Court agrees that employers whose 6 conduct survives the plurality's reasonableness test cannot be held 7 constitutionally liable (assuming the absence of pretext) . . . ."). 8 The employer does not meet its burden, however, if there 9 is no demonstrated nexus between the employee's speech and the 10 employer's operations. Where there is no such nexus, the state's 11 interest as an employer is not implicated, and restrictions on the 12 employee's speech will be subjected to the same scrutiny given to 13 restrictions imposed on citizens' speech by the state as sovereign. 14 See, e.g., NTEU, 513 U.S. at 465-66, 467 n.11, 470. 15 In NTEU, the Supreme Court considered a federal statute 16 that prohibited lower-level federal government employees from 17 accepting any compensation for making speeches or writing articles. 18 The plaintiffs were federal employees who, in their off-duty hours, 19 spoke or wrote on topics that usually bore no relationship to their 20 employment. While their speech was evidently on topics of public 21 concern--they were offered compensation by public groups and 22 entities for their talks and writings--the NTEU Court noted that, 23 "[w]ith few exceptions, the content of [plaintiffs'] messages has 24 nothing to do with their jobs and does not even arguably have any 25 adverse impact on the efficiency of the offices in which they work." 26 Id. at 465 (emphasis added); see id. ("Neither the character of the 27 authors, the subject matter of their expression, the effect of the -41- 1 content of their expression on their official duties, nor the kind 2 of audiences they address has any relevance to their employment." 3 (emphasis added)). Regulations implementing the statute "exclude[d] 4 a wide variety of performances and writings that would normally 5 appear to have no nexus with an employee's job." Id. at 476. With 6 "no nexus to Government employment," the Court stated, "no corrupt 7 bargain or even appearance of impropriety appears likely." Id. at 8 474. 9 The government's only argument in defense of the statute's 10 wholesale ban on the employees' acceptance of honoraria for their 11 off-duty speech was that the outright ban would be easier to 12 administer than a nexus-related prohibition that would require a 13 case-by-case comparison of the speech or article with the employee's 14 job. Although the Court had normally "'given greater deference to 15 government predictions of harm used to justify restriction of 16 employee speech than to predictions of harm used to justify 17 restrictions on the speech of the public at large,'" id. at 475 n.21 18 (quoting Waters, 511 U.S. at 673 (plurality opinion)), the NTEU 19 Court concluded that "[d]eferring to the Government's speculation 20 about the pernicious effects of thousands of articles and speeches 21 yet to be written or delivered would encroach unacceptably on the 22 First Amendment's protections," NTEU, 513 U.S. at 476 n.21. 23 Accordingly, the Court held that the "blanket burden on 24 the speech of nearly 1.7 million federal employees," speaking or 25 writing on their own time on topics unrelated to their employment, 26 "requires a much stronger justification than the Government's 27 dubious claim of administrative convenience." Id. at 474. -42- 1 The NTEU principle does not immunize an employee's 2 expressive activities--even those that take place during his off- 3 duty hours and outside of the workplace, and that purport to be 4 "about subjects not related to his employment"--when his employer's 5 "legitimate and substantial interests" are "compromised by his 6 speech." Roe, 543 U.S. at 81. The plaintiff in Roe, an officer of 7 the San Diego Police Department ("SDPD"), spent off-duty hours 8 displaying and selling on the internet videos that showed him 9 stripping off what was obviously a police uniform and masturbating. 10 The uniform Roe wore was not the specific uniform worn by San Diego 11 policemen, but he offered official San Diego police uniforms for 12 sale, along with other items such as underwear, police equipment, 13 and custom-made videos. His presentations did not include any 14 commentary on the workings or functioning of the San Diego police 15 department. When the SDPD ordered Roe to cease selling sexually 16 explicit videos or engaging in any similar conduct on the internet, 17 by mail, or through any other means of distribution to the public, 18 Roe only partially complied, continuing to purvey his first two 19 videos and offering to make custom videos. See Roe, 543 U.S. at 78- 20 79. After internal proceedings, Roe was discharged. He sued the 21 city, alleging that the termination violated his First Amendment 22 rights. The district court dismissed his claim on the ground that 23 his expressive conduct was not on a matter of public concern. The 24 court of appeals, citing NTEU, reversed, stating that Roe's conduct 25 was on a matter of public concern, had taken place while he was off 26 duty and away from his employer's premises, and was unrelated to his 27 employment. -43- 1 The Supreme Court reversed. The Court had "no difficulty 2 in concluding that Roe's expression does not qualify as a matter of 3 public concern under any view of the public concern test." Roe, 543 4 U.S. at 84. It also found NTEU entirely inapplicable because "[i]n 5 NTEU it was established that the speech was unrelated to the 6 employment and had no effect on the mission and purpose of the 7 employer," id. at 80. Roe's conduct, in contrast, brought the 8 police department into serious disrepute: 9 Although Roe's activities took place outside the 10 workplace and purported to be about subjects not 11 related to his employment, the SDPD demonstrated 12 legitimate and substantial interests of its own that 13 were compromised by his speech. Far from confining 14 his activities to speech unrelated to his 15 employment, Roe took deliberate steps to link his 16 videos and other wares to his police work, all in a 17 way injurious to his employer. The use of the 18 uniform, the law enforcement reference in the Web 19 site, the listing of the speaker [in his 20 advertising] as "in the field of law enforcement," 21 and the debased parody of an officer performing 22 indecent acts while in the course of official duties 23 brought the mission of the employer and the 24 professionalism of its officers into serious 25 disrepute. 26 Id. at 81. Although the court of appeals stated that SDPD had 27 conceded that Roe's activities were "'unrelated'" to his employment, 28 the Supreme Court reasoned that 29 the proper interpretation of the City's statement is 30 simply to underscore the obvious proposition that 31 Roe's speech was not a comment on the workings or 32 functioning of the SDPD. It is quite a different 33 question whether the speech was detrimental to the 34 SDPD. On that score the City's consistent position 35 has been that the speech is contrary to its 36 regulations and harmful to the proper functioning of 37 the police force. The present case falls outside 38 the protection afforded in NTEU. 39 Id. at 81-82; see id. at 84 ("The speech in question was detrimental 40 to the mission and functions of the employer."). In sum, to have a -44- 1 nexus to his employment, an employee's speech need not comment on 2 the workings or functioning of the employer's operation; it is 3 sufficient that that speech be detrimental to that operation. 4 B. The Record in the Present Case 5 1. Application of the Public Concern Test 6 With these principles in mind, we begin by addressing 7 plaintiffs' contention that Connick's public concern test is 8 inapplicable to claims asserting violation of the right to 9 expressive association and their concession in the district court 10 that their expressive conduct was not on a matter of public concern. 11 We conclude that both their concession--at least so far as 12 Piscottano, Kight, and Vincenzo are concerned--and their contention 13 are erroneous. 14 We note first our agreement with the district court that, 15 in order to prevail on a First Amendment freedom-of-expressive- 16 association claim, a government employee must show, inter alia, that 17 his expressive association involved a matter of public concern--just 18 as would a government employee complaining of a violation of his 19 right to freedom of speech. See, e.g., Cobb v. Pozzi, 363 F.3d 89, 20 102-07 (2d Cir. 2004). Given that freedom of speech is expressly 21 protected by the First Amendment and that freedom of expressive 22 association is not, the latter being deemed protected only as 23 derivative of freedom of speech, we see no logic in plaintiffs' 24 contention that they should be allowed to establish a violation of 25 the derivative right on less proof than is required for 26 establishment of a violation of the expressly protected right from -45- 1 which it is derived. See, e.g., id. at 105-07. 2 Second, as discussed above, the inquiry into whether the 3 speech at issue is on a matter of public concern is a question of 4 law for the court. Thus, concessions by the parties are not 5 necessarily dispositive, and our review of the record persuades us 6 that the concession by plaintiffs in this case is only partially 7 correct. 8 An individual's association with an organization can be 9 deemed to involve expression on a matter of public concern in either 10 of two ways. First, the organization itself may engage in advocacy 11 on a matter of public concern. If it does, the individual's 12 association with the organization may constitute, at least 13 vicariously, expressive conduct on a matter of public concern. See 14 generally Roberts, 468 U.S. at 622; Melzer v. Board of Education, 15 336 F.3d 185, 195-96 (2d Cir. 2003), cert. denied, 540 U.S. 1183 16 (2004). Second, even where the organization itself does not purport 17 to engage in advocacy on matters of public concern, the individual's 18 association with the organization may--although it does not 19 necessarily--constitute approval or an endorsement of the nature and 20 character of the organization. Such approval or endorsement itself 21 would constitute expressive conduct on a matter of public concern if 22 the nature or character of the organization is a matter of public 23 concern. 24 In the present case, plaintiffs have conceded that the 25 Outlaws is not an organization that speaks out on matters of public 26 concern, and the record as a whole supports that concession. There 27 was no evidence to the contrary; and Kight, for example, testified -46- 1 that what the Outlaws is "all about" is riding motorcycles, having 2 parties, and "hav[ing] fun." (Tr. 103; see also id. at 137 3 (Scappini: Outlaws functions are "social"); id. at 6 (Piscottano: 4 Outlaws is essentially "a social club").) Thus, we accept 5 plaintiffs' concession to the extent that it meant that they are not 6 engaged in expressive conduct on matters of public concern 7 vicariously by reason of advocacy by the OMC itself. 8 This does not, however, answer the question of whether 9 plaintiffs' own conduct in associating with that chapter constitutes 10 expressive conduct on a matter of public concern, given the history 11 and character of the national organization with which the 12 Connecticut chapter is affiliated and of other Outlaws chapters. 13 The NDIC reports numerous instances in which members of the Outlaws 14 in various parts of the country have engaged in violent criminal 15 activity, including rape, arson, bombings, and murder, and numerous 16 convictions and imprisonments of Outlaws members. (See Part I.A.1. 17 above.) Plainly, the nature of the organization with which the 18 Connecticut chapter is affiliated is a matter of public concern. 19 The conduct of three of these plaintiffs can easily be 20 seen as expressing their view--approval--of the Outlaws local 21 chapter, the national organization with which it is affiliated, and 22 other Outlaws chapters. DOC presented evidence that Piscottano and 23 Kight--even after resigning their membership--not only attended 24 several Outlaws events but also wore Outlaws colors. Vincenzo, even 25 though he has denied ever being a member, has likewise admitted 26 wearing Outlaws apparel. State Police Trooper Williams, an expert 27 in motorcycle gangs, testified that Outlaws colors are a source of -47- 1 pride (see Tr. 188); and Kight, when asked the significance of 2 wearing Outlaws colors, similarly testified that "[i]t's a proud 3 thing" (id. at 103). 4 Further, the criminal activity in other Outlaws chapters 5 is material here because, while plaintiffs repeatedly emphasize that 6 no member of the Connecticut chapter (qua Outlaw) has thus far been 7 accused or convicted of a crime, the Connecticut chapter's 8 affiliation with the national organization--and the resulting close 9 relationship with other Outlaws chapters--is one of the stated 10 attractions of associating with the Outlaws. Three of the 11 plaintiffs, when asked to describe the reasons for their involvement 12 in the Outlaws, responded, under oath, that one of their reasons was 13 that "as a Club member, I can travel anywhere in the world and be 14 welcomed as a brother." (E.g., Piscottano Answer to DOC 15 Interrogatory No. 8 (emphasis added); Kight Answer to DOC 16 Interrogatory No. 8 (same); Vincenzo Answer to DOC Interrogatory No. 17 8 (same).) (We note that Vincenzo gave this answer despite having 18 denied that he ever was a member of the Outlaws.) Kight, for 19 example, apparently received such a welcome in Florida. When asked 20 about occasions on which, despite his resignation, he was "permitted 21 to wear colors at club functions," he stated: 22 Well, I was just down in Daytona last month or maybe 23 four to six weeks ago, whatever, and I was down 24 there at a party down there and they brought the 25 colors down to me and I wore them while I was down 26 in Daytona. 27 (Tr. 104.) Thus, Piscottano, Kight, and Vincenzo treasure their 28 associations with members of other Outlaws chapters that may well be 29 conducting criminal enterprises. Their wearing of Outlaws colors -48- 1 and apparel plainly expressed their approval of the Outlaws and its 2 affiliated organizations. 3 The inference that their endorsement extends to other 4 chapters of the Outlaws is supported both by their interrogatory 5 answers described above, embracing association with Outlaws chapters 6 "anywhere in the world," and by their Complaint and in-court 7 testimony. In their Complaint, plaintiffs have taken the position, 8 contrary to the NDIC report, that other chapters have not engaged in 9 criminal activity. They alleged that 10 [t]he DOC Report contains information purportedly 11 gathered from an October 2002 "National Drug 12 Intelligence Center" publication and from an 13 anonymous source which is entirely false and without 14 basis in fact . . . . 15 (Complaint ¶ 18 (emphasis added).) And Piscottano, at the 16 preliminary injunction hearing, testified as follows: 17 Q. Th[e DOC 2003 Report] contains a whole 18 section which has at the beginning, the following 19 information was gathered from The National Drug 20 Intelligence Center publication dated October, 2002. 21 Have you had a chance to review that? 22 A. Yes. 23 Q. Is that information accurate? 24 A. No. 25 (Tr. 14-15 (emphases added).) Thus, in denying that other Outlaws 26 chapters have engaged in criminal activity, plaintiffs have aligned 27 themselves with the Outlaws and against local, State, and national 28 law enforcement agencies. (See also Transcript of December 22, 2003 29 SD Interview of Piscottano, at 12, in which Piscottano expressed 30 outrage that a State Police Homeland Security/SWAT team would serve 31 a search warrant during the Outlaws Christmas party.) -49- 1 In sum, on this record, we think it plain that Piscottano, 2 Kight, and Vincenzo, by, inter alia, repeatedly consorting with the 3 Outlaws and wearing Outlaws colors and apparel in public--even at 4 such times as they were not members of the Outlaws--engaged in 5 expressive activity approving of the nature of the Connecticut 6 chapter of the Outlaws, of the national Outlaws organization, and of 7 other Outlaws chapters. 8 The fact that law enforcement agencies believe the Outlaws 9 and many of its chapters engage in criminal activity is sufficient 10 in itself to make the nature of those entities a matter of public 11 concern. In addition, in this case we note that public concern was 12 reflected in two other ways. First, the investigation into 13 plaintiffs' activities was sparked by a letter to the Commissioner 14 from a member of the public, expressing apprehension at the prospect 15 of violent encounters between the Outlaws and the Hells Angels, 16 complaining that the motorcycle clubs were terrorizing ordinary 17 citizens, and protesting that patch-wearing members of the Outlaws 18 were State-employed correctional officers. Second, these officers' 19 association with the Outlaws was the subject of a freedom-of- 20 information inquiry from the press. We conclude that the expressive 21 conduct of Piscottano, Kight, and Vincenzo, demonstrating pride in 22 and approval of the organization thus criticized by others, 23 constituted speech by these three plaintiffs on a subject that is a 24 matter of public concern. 25 While we conclude that the nature and character of the 26 Outlaws is a topic of public concern, we have not seen any evidence 27 in the record that Scappini engaged in expressive conduct on that -50- 1 topic. The record gives no indication that he ever wore Outlaws 2 colors. His response to interrogatories, unlike those of the other 3 three plaintiffs, did not treasure the worldwide welcomes by members 4 of other Outlaws chapters. And SD found no evidence that he 5 attended any Outlaws events after he received the DOC 2003 Report 6 that detailed criminal activity by other Outlaws members around the 7 United States. We conclude that the record does not support an 8 expressive association claim by Scappini because, if he engaged in 9 any expressive conduct, it was not shown to be on a matter of public 10 concern. His expressive association claim was properly dismissed on 11 that basis. 12 With respect to Piscottano, Kight, and Vincenzo, our 13 conclusions (a) that the nature and activities of the Outlaws 14 national organization and its affiliated chapters are a matter of 15 public concern, and (b) that these three plaintiffs engaged in 16 expressive conduct approving of the Outlaws and its chapters, mean 17 that our analysis of their First Amendment claims must proceed to 18 the balancing phase of the Pickering test. That said, we have no 19 difficulty in concluding that the record shows that the balance is 20 in favor of DOC. 21 2. DOC's Evidence as to Likely Disruption of Its Operations 22 Although plaintiffs contend that any balancing favors them 23 because their association with the Outlaws is unrelated to their 24 employment, occurring away from the workplace in their off-duty 25 hours, we reject their contention that there is no nexus between 26 that association and DOC's operations. The evidence sufficiently -51- 1 shows that DOC conducted reasonable investigations (see Part I.A., 2 I.B., and I.C. above) and arrived at a good-faith conclusion that 3 having correctional officers who are associated with the Outlaws is 4 detrimental to DOC operations and reflects negatively on DOC. 5 Although DOC presented no evidence that actual disruptions 6 had yet occurred, the record as a whole, including the testimony of 7 its top-ranking officials, who are experts in prison administration 8 and/or the problems of gang violence, amply described threats to 9 safety, potentials for disruption, potential conflicts of interest, 10 and interference with the integrity of DOC's operations. 11 For example, gang fights in which correctional officers 12 are involved--such as the altercation in which, according to the 13 Chaser's Café employee, Piscottano and Kight, wearing Outlaws 14 colors, were involved and Kight was hit in the face by a member of 15 the Crossroads Motorcycle Club--reflect negatively on the 16 Department. Such fights also frequently imperil innocent 17 bystanders. At the Chaser's Café altercation, for example, gunshots 18 were fired. 19 Further, DOC's concerns for the safety of its staff in the 20 prison setting are plainly implicated whenever, for example, there 21 is violent interaction among inmates (see, e.g., Part I.C.5. above, 22 describing DOC's experiences with respect to the gang-related 23 bludgeoning of one inmate and fire-bombing of another), or an inmate 24 attack on a prison guard (see id., describing Hells Angels leader's 25 statement to State Police officer that correctional officers who 26 were associated with the Outlaws were thereby "in jeopardy"). DOC 27 has a legitimate interest in reducing such risks, without having to -52- 1 wait for emergencies. 2 Plaintiffs' associations with the Outlaws also had the 3 potential to interfere with DOC's collaboration with other law 4 enforcement agencies. For example, Lantz testified that DOC staff 5 members participate in task forces focusing on gang activity. The 6 allegiance of any DOC employees to the Outlaws could jeopardize 7 those working relationships by raising questions as to whether 8 employees of DOC could be relied on to, inter alia, maintain 9 confidentiality as to planned surveillances and executions of search 10 warrants. 11 Moreover, DOC has an interest in avoiding even the 12 appearance that its correctional officers have conflicts of 13 interest. For example, as a general matter, any correctional 14 officer who wished to become a member of the Outlaws would have an 15 incentive to give favorable treatment to an inmate who was already 16 an Outlaws member, for the Outlaws bylaws require that for a chapter 17 to elect a new member, the membership's vote must be unanimous. As 18 for Kight in particular, after he resigned his Outlaws membership, 19 members of the Outlaws repeatedly did him the favor, in disregard of 20 their bylaws, of bringing him Outlaws colors to wear. Kight 21 testified that the Outlaws "allowed me to wear them because they 22 have a lot of respect for me and they know that I still love the 23 club . . . ." (Tr. 103.) Any acceptance of favors raises the 24 prospect that the favors will be returned, creating the appearance 25 of a potential conflict of interest. And Kight's acceptance of 26 these favors out of his "love [for] the club" plainly gave him a 27 potential conflict of interest if there were an inmate who happened -53- 1 to be a member of the Outlaws. 2 Further, because of rivalry between the Outlaws and the 3 Hells Angels, a correctional officer who is associated with the 4 Outlaws might be tempted to deny fair treatment to an inmate who was 5 a member of the Hells Angels. Even in the absence of such 6 unfairness, the very fact that the officer was associated with the 7 Outlaws could give an inmate who was a member of the Hells Angels 8 (or of any other rival club) a plausible claim that he was denied 9 fair treatment by the officer or, in a disciplinary hearing against 10 the inmate, a basis for challenging the testimony by the Outlaws- 11 associated officer for bias. 12 Nor is the thought that an Outlaws-affiliated correctional 13 officer might mistreat an inmate member of a rival gang at all 14 fanciful. According to Piscottano, the Outlaws itself instructed 15 him not to abuse Outlaws rivals: 16 When I was a member of the Outlaws Motorcycle Club 17 ("Club"), I was expressly instructed that under no 18 circumstances should I take action of any kind, or 19 retaliate in any way, against any member of any 20 other motorcycle club, should I happen to encounter 21 one in the course of my work as a correctional 22 officer. According to the Club, everyone is neutral 23 in the prison setting, everyone gets along and there 24 is no competition or rivalry of any kind. 25 (Affidavit of Gary Piscottano dated February 7, 2005, ¶ 9.) Even 26 leaving aside the contraindicated suggestion that there are no 27 frictions between rival gang members in prison, DOC need not rely on 28 the proposition that its correctional officers will perform their 29 jobs properly because they have been so instructed by the Outlaws. 30 We conclude that DOC established that the conduct of 31 Piscottano, Kight, and Vincenzo, expressing their approval of the -54- 1 nature and character of the Outlaws, had the potential in several 2 ways to disrupt and reflect negatively on DOC's operations, and that 3 DOC's interest in maintaining the efficiency, security, and 4 integrity of its operations outweighed the associational interests 5 of those plaintiffs. Accordingly, plaintiffs' freedom-of- 6 expressive-association claims were properly dismissed. 7 III. FREEDOM OF INTIMATE ASSOCIATION 8 Plaintiffs contend that the district court erred in 9 dismissing their intimate association claims on the ground that the 10 Outlaws is not a selective organization, and that the court erred in 11 failing to consider that plaintiffs have close personal friendships 12 with Outlaws members. We disagree. 13 Although "[t]he source of the intimate association right 14 has not been authoritatively determined," Adler v. Pataki, 185 F.3d 15 35, 42 (2d Cir. 1999); see id. at 42-44 (discussing cases that frame 16 the right as either an implied First Amendment right or as a 17 fundamental liberty protected by the Due Process Clause of the 18 Fourteenth Amendment), the relationships that have been recognized 19 as entitled to protection under either Amendment are "distinguished 20 by such attributes as relative smallness, a high degree of 21 selectivity in decisions to begin and maintain the affiliation, and 22 seclusion from others in critical aspects of the relationship," 23 Roberts, 468 U.S. at 620; see also id. (among the factors to be 24 considered are "size, purpose, policies, selectivity, [and] 25 congeniality"). Relationships that "exemplify" constitutionally -55- 1 protected intimate associations "are those that attend the creation 2 and sustenance of a family," such as "marriage," "childbirth," "the 3 raising and education of children," and "cohabitation with one's 4 relatives." Id. at 619; see, e.g., Pi Lambda Phi Fraternity, Inc. 5 v. University of Pittsburgh, 229 F.3d 435, 438 (3d Cir. 2000) 6 ("intimate association" means "certain close and intimate human 7 relationships like family relationships"). 8 Entities such as "large business enterprise[s]," on the 9 other hand, are "remote from the concerns giving rise to this 10 constitutional protection." Roberts, 468 U.S. at 620. When 11 presented with the issue, the Supreme Court has consistently held 12 that large social clubs are not constitutionally protected 13 "intimate" associations. See, e.g., Board of Directors of Rotary 14 International v. Rotary Club of Duarte, 481 U.S. 537, 546 (1987) 15 ("Duarte") (local clubs, ranging in size from fewer than 20 to 900 16 members, did not implicate the right of intimate association); 17 Roberts, 468 U.S. at 621 (same with respect to local clubs having 18 more than 400 members); see also Pi Lambda Phi Fraternity, Inc. v. 19 University of Pittsburgh, 229 F.3d at 438, 442 (same with respect to 20 college fraternity ranging from 22 to 80 members). 21 In the present case, the district court ruled that 22 plaintiffs' affiliation with the Outlaws was not a constitutionally 23 protected intimate association because there was no evidence that 24 the OMC is either a small group or a particularly selective group 25 with respect to its membership or attendance at its functions: 26 Although neither party has specified the 27 precise size of the Outlaws, it is apparent that it 28 is not a small group. . . . The Outlaws is an 29 international organization with chapters in the -56- 1 United States, Canada, Europe and Australia. . . . 2 Within the United States, there are chapters located 3 in many states, including Wisconsin, Florida, 4 Indiana, North Carolina, Massachusetts, New 5 Hampshire, New York and Connecticut. . . . Indeed, 6 according to Plaintiff Gary Piscottano, "when an 7 [Outlaws] member dies, hundreds of members attend 8 the funeral and offer support and comfort to the 9 family." 10 Piscottano II, 2005 WL 1424394, at *7 (quoting Piscottano Answer to 11 DOC Interrogatory No. 8) (emphasis in Piscottano II). The court 12 continued: 13 Nor is the Outlaws a particularly selective 14 organization. To be sure, membership in the Outlaws 15 is not open to the general public. Membership is 16 extended only by invitation and involves a 17 probationary period. . . . Nevertheless, nothing in 18 the record reveals any onerous requirements for 19 membership. According to Plaintiffs, the group 20 "embraces" those who chose a "non-mainstream, non- 21 traditional, unconventional lifestyle, appearance, 22 ideals and/or job." . . . . 23 It is also undisputed that many of the Outlaws' 24 activities and events--such as motorcycle rides, 25 cookouts and parties--are freely open to non- 26 members. . . . This lack of seclusion from the 27 public also militates against a finding that the 28 Outlaws is the type of intimate association that 29 justifies First Amendment protection. See Roberts, 30 468 U.S. at 621 (finding significant that "numerous 31 non-members . . . regularly participate in a 32 substantial portion" of the Jaycees activities); 33 Duarte, 481 U.S. at [547] (noting that "[m]any of 34 the Rotary Clubs' central activities are carried on 35 in the presence of strangers") . . . . 36 Piscottano II, 2005 WL 1424394, at *7 (quoting Plaintiffs' Rule 37 56(a)(1) Statement, submitted in support of their cross-motion for 38 summary judgment, ¶¶ 32-33). 39 The district court's description was taken from statements 40 of the plaintiffs themselves in their answers to interrogatories, in 41 their responses to defendants' Rule 56(a)(1) Statement of Undisputed 42 Facts, and in plaintiffs' own statement of the facts that plaintiffs -57- 1 contended were undisputed. We have been pointed to no evidence in 2 the record that shows the existence of any material disputed fact on 3 these issues, and we see no error in the district court's 4 application of the above principles. 5 Nor do we see any error in the court's rejection of 6 plaintiffs' contention that they were disciplined for merely 7 associating with friends who happened to be members of the Outlaws. 8 The notices of termination and counseling bespoke no such rationale; 9 nor did the testimony or documentary evidence. For example, at the 10 preliminary injunction hearing, Murphy was asked whether Vincenzo, 11 who at that time had simply been counseled, would be subject to 12 discipline under Directive 2.17 for riding his motorcycle with, 13 e.g., Piscottano, who frequently consorted with the Outlaws and had 14 been discharged. Murphy distinguished between a correctional 15 officer's mere association with a friend who happened to be 16 affiliated with the Outlaws and an officer's apparent association 17 with the Outlaws organization itself: 18 If they're riding with the Outlaws with all patch 19 members, that may be an issue. If he's friends with 20 Mr. Piscottano in an independent capacity, I can't 21 stop that. But once it crosses the line where it 22 appears to be attached to the Outlaws as an 23 organization, a criminal enterprise, it will 24 probably be looked at. 25 (Tr. 270-71 (emphases added).) 26 In sum, the evidence in the record does not support 27 plaintiffs' contention that DOC imposed discipline on the basis of 28 their close personal friendships. We affirm the dismissal of 29 plaintiffs' intimate association claim substantially for the reasons 30 stated by the district court. -58- 1 IV. THE VAGUENESS CHALLENGES 2 Finally, plaintiffs contend that the imposition of 3 discipline on them pursuant to Directive 2.17 violated their rights 4 to due process, arguing that that regulation, in prohibiting a 5 correctional officer from engaging in behavior that "could . . . 6 reflect negatively on the Department of Correction," is 7 impermissibly vague. Given that the due process doctrine of 8 vagueness is designed to ensure that, before risking a deprivation 9 of liberty or property, a person have fair notice of the type of 10 conduct that is prohibited, we conclude that plaintiffs' due process 11 claims were properly dismissed. 12 The Due Process Clause of the Fourteenth Amendment 13 provides that "[n]o State shall . . . deprive any person of life, 14 liberty, or property, without due process of law." U.S. Const. 15 amend. XIV, § 1. "It is a basic principle of due process that an 16 enactment is void for vagueness if its prohibitions are not clearly 17 defined." Grayned v. City of Rockford, 408 U.S. 104, 108 (1972). 18 Thus, a law or regulation whose violation could lead to such a 19 deprivation must be crafted with sufficient clarity to "give the 20 person of ordinary intelligence a reasonable opportunity to know 21 what is prohibited" and to "provide explicit standards for those who 22 apply them." Id. 23 "Condemned to the use of words," however, "we can never 24 expect mathematical certainty from our language." Id. at 110. 25 Thus, a regulation need not achieve "meticulous specificity," which 26 would come at the cost of "flexibility and reasonable breadth," id. -59- 1 (internal quotation marks omitted); and regulations "are not 2 automatically invalidated as vague simply because difficulty is 3 found in determining whether certain marginal offenses fall within 4 their language," United States v. National Dairy Products Corp., 372 5 U.S. 29, 32 (1963). Rather, the question of whether a statute or 6 regulation is unconstitutionally vague is determined by whether it 7 afforded fair notice to the plaintiff to whom it was applied. "In 8 determining the sufficiency of the notice," a regulation "must of 9 necessity be examined in the light of the conduct with which a 10 defendant is charged." Id. at 33. "A plaintiff who engages in some 11 conduct that is clearly proscribed cannot complain of the vagueness 12 of the law as applied to the conduct of others." Village of Hoffman 13 Estates v. Flipside, Hoffman Estates, Inc., 455 U.S. 489, 495 (1982) 14 ("Hoffman"); see, e.g., Parker v. Levy, 417 U.S. 733, 756 (1974) 15 ("One to whose conduct a statute clearly applies may not 16 successfully challenge it for vagueness."). 17 Further, the Supreme Court has "expressed greater 18 tolerance of enactments with civil rather than criminal penalties 19 because the consequences of imprecision are qualitatively less 20 severe." Hoffman, 455 U.S. at 498-99. And it has indicated that 21 generalized language may appropriately be used to set out standards 22 of conduct for employees. See, e.g., Arnett v. Kennedy, 416 U.S. 23 134, 159 (1974) (plurality opinion). Accordingly, prohibitions 24 phrased in general terms have been upheld when they were plainly 25 applicable to the conduct of the employee plaintiff, despite the 26 existence of questions as to whether they would give fair notice 27 with respect to other, hypothetical, conduct at the periphery. See, -60- 1 e.g., Janusaitis v. Middlebury Volunteer Fire Department, 607 F.2d 2 17, 27-28 (2d Cir. 1979) (regulation barring "unbecoming conduct 3 detrimental to the welfare or good name of [a Fire] Department" was 4 not impermissibly vague as applied to a fireman who had been warned 5 that if he continued to publish defamatory allegations about the 6 department, he would be fired for violating the regulation); diLeo 7 v. Greenfield, 541 F.2d 949, 953 (2d Cir. 1976) (provision allowing 8 termination of a teacher's employment for "other due and sufficient 9 cause" was not vague as applied to a teacher charged with exhibiting 10 improper conduct toward students); Allen v. City of Greensboro, 11 North Carolina, 452 F.2d 489, 491 (4th Cir. 1971) (regulation 12 barring conduct "unbecoming an officer and a gentleman" was not 13 vague as applied to a policeman accused of making improper advances 14 toward a woman in connection with an official investigation). 15 In Arnett, the Supreme Court considered a vagueness 16 challenge to a provision of the Lloyd-La Follette Act that 17 authorized a federal agency to remove or suspend without pay a 18 nonprobationary federal employee "for such cause as will promote the 19 efficiency of the service," 5 U.S.C. § 7501(a) ("[a]n individual in 20 the competitive service may be removed or suspended without pay only 21 for such cause as will promote the efficiency of the service") 22 (repealed by the Civil Service Reform Act of 1978, Pub. L. No. 95- 23 454, § 204(a), 92 Stat. 1111, 1134). A majority of the Court found 24 the provision not impermissibly vague. See Arnett, 416 U.S. at 158- 25 61 (plurality opinion); id. at 164 (opinion of Powell, J. (agreeing 26 with the reasoning of the plurality opinion on this issue)); id. at 27 177 (opinion of White, J. (same)). The Arnett Court noted: -61- 1 [T]here are limitations in the English language with 2 respect to being both specific and manageably brief, 3 and it seems to us that although the prohibitions 4 may not satisfy those intent on finding fault at any 5 cost, they are set out in terms that the ordinary 6 person exercising ordinary common sense can 7 sufficiently understand and comply with, without 8 sacrifice to the public interest. [If t]he general 9 class of offense to which . . . [the provisions are] 10 directed is plainly within [their] terms . . . , 11 [they] will not be struck down as vague, even though 12 marginal cases could be put where doubts might 13 arise. 14 Arnett, 416 U.S. at 159 (plurality opinion) (internal quotation 15 marks omitted). 16 Congress sought to lay down an admittedly general 17 standard, not for the purpose of defining criminal 18 conduct, but in order to give myriad different 19 federal employees performing widely disparate tasks 20 a common standard of job protection. We do not 21 believe that Congress was confined to the choice of 22 enacting a detailed code of employee conduct, or 23 else granting no job protection at all. 24 Id. 25 Although the Arnett Court noted that "[t]he phrase 'such 26 cause as will promote the efficiency of the service' as a standard 27 of employee job protection is without doubt intended to authorize 28 dismissal for speech as well as other conduct," id. at 160 29 (plurality opinion), the Court observed that Pickering makes clear 30 that "'the State has interests as an employer in regulating the 31 speech of its employees that differ significantly from those it 32 possesses in connection with regulation of the speech of the 33 citizenry in general,'" and that those interests may allow "the 34 discharge of [the] employee . . . based on his speech without 35 offending guarantees of the First Amendment." Arnett, 416 U.S. at 36 160-61 (plurality opinion) (quoting Pickering, 391 U.S. at 568). 37 Citing the "essential fairness of this broad and general removal -62- 1 standard, and the impracticability of greater specificity," the 2 Arnett Court concluded that 3 [b]ecause of the infinite variety of factual 4 situations in which public statements by Government 5 employees might reasonably justify dismissal for 6 "cause," we conclude that the Act describes, as 7 explicitly as is required, the employee conduct 8 which is ground for removal. 9 416 U.S. at 161 (plurality opinion). 10 A. Directive 2.17 and the Notice Given to All Plaintiffs 11 Directive 2.17 sets out Standards of Conduct outlining 12 conduct that is mandatory and conduct that is prohibited. Insofar 13 as plaintiffs challenge it for vagueness, Directive 2.17 provides 14 that employees are prohibited from "[e]ngag[ing] in unprofessional 15 . . . behavior, both on and off duty, that could in any manner 16 reflect negatively on the Department of Correction." 17 In September 2003, all of the plaintiffs were interviewed 18 by SD with respect to their membership, affiliation, or association 19 with the Outlaws. Two of them admitted to having been members in 20 the past; all of them stated that they attended Outlaws events even 21 as nonmembers. All of them were questioned about criminal activity 22 by Outlaws members. They all denied knowledge of any such activity. 23 (See DOC 2003 Report at 7 (Vincenzo: "I have no knowledge of any 24 illegal activity by the Outlaws Motorcycle club."); id. (Piscottano: 25 "I do not know that the Outlaws are involved in any criminal 26 activity, if they were I wouldn't be there."); id. at 10 (Kight: "I 27 am not aware of any illegal activity by any of the members of the 28 club, unless drinking a few beers is considered an illegal activity. 29 There may be criminal activity in other states but none in -63- 1 Connecticut as far as I know."); id. at 11 (Scappini: "I am not 2 aware of or seen [sic] any illegal activity by any member of the 3 Outlaws Motorcycle Club.").) Plainly, after being questioned by SD 4 about criminal activity by Outlaws members, any reasonable person 5 would be aware that such activity was a matter of concern to DOC. 6 The DOC 2003 Report, described in Part I.B.2. above, 7 prepared after the SD interviews of plaintiffs, began by stating 8 that 9 [o]n August 1, 2003, Commissioner Theresa C. Lantz 10 forwarded a referral to the Director of Security for 11 an official investigation into the allegations that 12 several Correction Officers are members or 13 associates of the Outlaws Motorcycle Club. 14 (DOC 2003 Report at 1.) As described in Parts I.A.1., I.A.2., and 15 I.B.2. above, the DOC 2003 Report proceeded to detail information 16 DOC had received from federal, State, and local law enforcement 17 agencies as to widespread criminal activities by the OMC, which had 18 led to scores of prosecutions and convictions. (See id. at 1-6.) 19 These Outlaws activities included trafficking in ecstasy, marijuana, 20 and cocaine; selling stolen goods; exploiting female associates as 21 prostitutes; and engaging in racketeering through the use of violent 22 crimes such as arson, bombings, and murder. 23 The DOC Report described law enforcement agency 24 surveillances of the Connecticut chapter of the Outlaws during which 25 each of the plaintiffs had been observed attending Outlaws events. 26 (See id. at 2.) It described SD's interviews with each plaintiff on 27 the subject of his involvement with the Outlaws, and recorded the 28 statements of Piscottano and Kight that although they had for a time 29 been members of the Outlaws they had resigned in early or mid-2003. -64- 1 (See id. at 6, 10.) And it described observations of Kight wearing 2 Outlaws colors subsequent to his resignation. (See id. at 15.) 3 The DOC Report's Summary stated, inter alia, that all of 4 the plaintiffs had "positively been identified as being involved or 5 associating with the Outlaws Motorcycle Club." (Id. at 14.) The 6 DOC Report concluded that each of the plaintiffs had violated 7 various provisions of Directive 2.17, including its prohibition 8 against "[e]ngag[ing] in unprofessional or illegal behavior, both on 9 and off duty, that could in any manner reflect negatively on the 10 Department." (Id. at 16-18.) 11 Each plaintiff was furnished with a copy of the DOC 12 Report. And each was notified that he would be given a Loudermill 13 hearing and an opportunity to, inter alia, dispute the allegations 14 of the DOC Report. (See, e.g., Complaint ¶ 20 ("On or about 15 November 20, 2003 Plaintiffs were provided with a copy of the DOC 16 Report and were ordered to report to DOC for pre-disciplinary 17 hearings. At those hearings, Plaintiffs were warned that as a 18 result of the violations outlined in the DOC Report, they could be 19 subject to discipline, up to and including termination.").) 20 Accordingly, although plaintiffs profess to have had no 21 idea that any Outlaws members in any OMC chapters had engaged in any 22 criminal activity, the record shows beyond cavil that plaintiffs 23 were on notice at least as early as November 20, 2003, (a) that law 24 enforcement agencies had copious information that Outlaws chapters 25 across the nation were engaging in criminal activity, and (b) that 26 DOC considered that the affiliation of its correctional officers 27 with the Outlaws would pose a potential conflict of interest and -65- 1 reflect negatively on the Department, in violation of Directive 2 2.17. And although plaintiffs contend that the phrase "could in any 3 manner reflect negatively on the Department" did not provide them 4 with reasonable notice that their activities with the Outlaws in 5 their free time were prohibited, that contention defies common 6 sense. That provision of Directive 2.17 expressly refers to 7 activities on or "off duty"; and it is not beyond the intelligence 8 of an ordinary person, much less that of a correctional officer, to 9 recognize that a criminal-justice-system officer's association with 10 an organization whose affiliates engage in criminal activity 11 reflects negatively on the agency that employs him. As the DOC 12 officials stated at the preliminary injunction hearing, it would be 13 difficult to fashion a directive that anticipated the entire range 14 of human behavior and specified every instance of prohibited conduct 15 (see Tr. 276); but surely conduct that could reflect negatively on 16 a criminal justice agency "inherent[ly]" encompasses "association 17 with . . . known criminal enterprises" (Tr. 363). 18 Finally, although plaintiffs argue that they had no 19 personal knowledge of any ongoing criminal activity by members of 20 the Connecticut chapter of the Outlaws or members of other Outlaws 21 chapters, and have taken the position that the NDIC Report of 22 criminal activity on the part of the Outlaws in other parts of the 23 United States is "entirely false and without basis in fact" 24 (Complaint ¶ 18), those arguments provide no support for their claim 25 that Directive 2.17 is impermissibly vague. It is undisputed that 26 DOC had received reports from several law enforcement agencies that 27 the Outlaws national organization and affiliated chapters were -66- 1 engaged in criminal activity (see, e.g., Plaintiffs' Responding Rule 2 56(a)(2) Statement ¶ 17 (admitting that the NDIC Report (see Part 3 I.A.1. above) "set forth" "allegations" that, inter alia, members of 4 the Outlaws had engaged in and been prosecuted for, convicted of, 5 and imprisoned on account of various crimes including racketeering, 6 robberies, bombings, and murder)). It is indisputable that DOC 7 credited those reports. (See, e.g., Plaintiffs' Summary Judgment 8 Memorandum at 48 ("Defendants' concerns about Club affiliation were 9 based upon their view that the Club was a criminal enterprise.").) 10 And in November 2003 plaintiffs were apprised in writing of those 11 reports and DOC's concern. (See, e.g., Complaint ¶ 20.) 12 In sum, each plaintiff had been questioned in September 13 2003 as to his knowledge of any criminal activity by Outlaws 14 members, questioning that sufficed to alert him that DOC was 15 concerned that there might be such activity and concerned about 16 employing correctional officers who were members or associates of 17 the Outlaws. And each plaintiff had explicit notice at least as 18 early as November 2003 that DOC considered the Connecticut chapter 19 of the Outlaws to be affiliated with an organization that engaged in 20 criminal activity and considered that a correctional officer's 21 affiliation with the Outlaws would reflect negatively on the 22 Department. 23 B. Application of Directive 2.17 to the Individual Plaintiffs 24 Despite the DOC concerns that were imparted to plaintiffs 25 in the fall of 2003, three of the plaintiffs engaged in conduct 26 thereafter that plainly fell within the scope of Directive 2.17's -67- 1 prohibition against conduct that could reflect negatively on the 2 Department. 3 1. The Continued Conduct of Kight 4 Following his September 2003 interview, Kight continued 5 his public relationship with the Outlaws, wearing Outlaws colors. 6 In October 2003, he was involved in an altercation at Chaser's Café. 7 He was knocked unconscious, and gunshots were fired. An employee at 8 that café identified Kight and several others, all wearing Outlaws 9 colors, and stated that Kight had been struck in the face by a 10 member of a rival gang. Kight was hospitalized with a broken jaw 11 and broken nose. Although he maintained that he had suffered those 12 injuries by falling in his bathtub, the State Police report stated 13 that his injuries were inconsistent with such a fall but consistent 14 with his having been struck in an altercation. The involvement of 15 a DOC correctional officer, wearing Outlaws colors, in a public 16 altercation at which shots were fired surely could reflect 17 negatively on the Department. 18 Kight was repeatedly allowed by the Outlaws to wear 19 Outlaws colors despite having resigned his membership. He explained 20 that Outlaws members brought him the colors out of their "respect" 21 for him and because of their knowledge that he "still love[d] the 22 club." (Tr. 103.) Regardless of whether members of any other 23 Outlaws chapters were involved in criminal activity, the granting of 24 such favors to Kight created the possibility that he might grant 25 favors in return within the prison setting; this plainly exposed DOC 26 to potential criticism. Such favors could take the form not only of -68- 1 giving preferential treatment to an inmate who was a member of the 2 Outlaws, but also of giving unduly harsh treatment to an inmate who 3 was a member of a rival gang. And if a member of a rival gang 4 accused Kight of abuse, even an unfounded accusation would place DOC 5 in the unfavorable position of having to defend without the ability 6 to deny Kight's conflict of interest. Similarly, if there were a 7 prison disciplinary hearing against such an inmate and Kight were 8 called to testify, his credibility would be subject to attack for 9 his pro-Outlaws bias against the rival gang. Thus, Kight's repeated 10 acceptance of favors from the Outlaws compromised his credibility 11 and potentially threatened the integrity of prison disciplinary 12 proceedings. Plainly such possibilities, especially once DOC had 13 learned of Kight's close association with the Outlaws, would reflect 14 negatively on DOC. 15 In November 2003, Kight was served with the DOC 2003 16 Report that concluded that his continued participation in Outlaws 17 events and wearing of Outlaws colors violated Directive 2.17's 18 prohibition against conduct that could reflect negatively on DOC. 19 Even had Kight not been on notice since September 2003 that DOC 20 viewed such conduct as violating Directive 2.17, the DOC Report 21 indisputably gave him such notice, as well as notice of the various 22 law enforcement agencies' information as to widespread criminal 23 activity on the part of the Outlaws national organization and 24 affiliated chapters. 25 Finally, Kight's Loudermill hearing was held on December 26 4, 2003, and he was "warned" at that hearing "that as a result of 27 the violations outlined in the DOC Report, []he[] could be subject -69- 1 to discipline, up to and including termination" (Complaint ¶ 20). 2 Nonetheless, Kight proceeded to attend the Outlaws Christmas party 3 on December 20, 2003, wearing Outlaws colors. His wearing of 4 Outlaws colors showed that he was "proud" of the organization. (Tr. 5 103.) It surely requires no special intelligence to realize that 6 Kight's repeated displays of his pride in being associated with a 7 group believed by every level of law enforcement to be affiliated 8 with an organization engaged in widespread criminal activity could 9 reflect negatively on the Department. 10 In sum, the undisputed facts of record make it clear that 11 Kight received fair notice that the Outlaws-related activities in 12 which he engaged after September 2003 would violate Directive 2.17's 13 prohibition against conduct that could reflect negatively on DOC. 14 Kight's vagueness claim was properly dismissed. 15 2. The Continued Conduct of Piscottano 16 Piscottano too continued his open association with the 17 Outlaws in the fall and winter of 2003. He sought, however, to 18 overturn his discharge in part by asserting that he knew of no 19 criminal activity on the part of the Outlaws and claiming that in 20 fact the NDIC report of such criminal activities was not accurate 21 (see Tr. 14-15), and in part by stating that he had received advice 22 indirectly from a DOC warden, Larry Myers, and a supervisor, Michael 23 Lajoie, that a correctional officer's association with the Outlaws 24 would not violate DOC policies so long as the officer himself was 25 not involved in criminal activity. Piscottano's contentions provide 26 no basis for reversal, given the concerns communicated to him by DOC -70- 1 during and after his September 2003 interview. 2 In some circumstances, advice from officials as to the 3 propriety of proposed conduct may indeed justify an individual in 4 believing that his planned conduct is not prohibited. In Cox v. 5 Louisiana, 379 U.S. 559 (1965), for example, the Supreme Court 6 overturned a conviction for violation of a statute that prohibited 7 protests "near" a courthouse, because police officers had advised 8 the appellant that his planned demonstration across the street from 9 the courthouse would not violate that prohibition, and the 10 protestors proceeded to hold their demonstration at the expressly 11 approved location. See id. at 571 ("after the public officials 12 acted as they did, to sustain appellant's later conviction for 13 demonstrating where they told him he could" would be inconsistent 14 with due process). As discussed below, the advice received by 15 Piscottano, in contrast to that received by the appellant in Cox, 16 was not received directly from officials, was not contemporaneous 17 with the conduct that led to his dismissal, and had become clearly 18 obsolete--at best--as a result of DOC's direct dealings with 19 Piscottano prior to the conduct that led to his dismissal. 20 Piscottano's evidence that he had received advice that his 21 association with the Outlaws would not violate DOC regulations, so 22 long as he himself did not engage in criminal activity, consisted 23 principally of the affidavit of Sabettini, which stated, in relevant 24 part, as follows: 25 Some time in 2001, I spoke to Warden Meyers [sic], 26 then Warden of NCI [the correctional institution to 27 which Sabettini was assigned], concerning my 28 association with the Club. Later in the year I 29 spoke to Major Lajoie about my association with the 30 Club. Both Meyers [sic] and Lajoie informed me that -71- 1 this association would not pose a problem, as long 2 as I was not involved in any criminal activities. I 3 relayed this information to Gary Piscottano. 4 (Affidavit of Randy Sabettini dated April 23, 2004, ¶ 6.) The 5 statement by Sabettini that he had inquired of his supervisors 6 "concerning [his] association with the Club" is silent as to 7 precisely what information he conveyed to them in seeking their 8 advice. Nor does Sabettini in his affidavit identify the time 9 period when he relayed information to Piscottano. (Piscottano 10 himself could only say that he had received the information from 11 Sabettini prior to September 2003.) However, any information 12 relayed from the "2001" conversations to which Sabettini referred 13 must have concerned his association with an Outlaws chapter other 14 than the Connecticut chapter, for the Connecticut chapter of the 15 Outlaws was not founded until 2002. 16 SD, having been informed early in its investigations that 17 Sabettini had at some point made some inquiry of his supervisors 18 with respect to his association with the Outlaws, interviewed Myers 19 and Lajoie. Neither Myers nor Lajoie provided any information with 20 respect to any conversation with Sabettini in 2001; but both 21 indicated that they had had conversations with him in mid- or late 22 2002. Myers stated: 23 I can't recall if [Sabettini] specifically mentioned 24 the Outlaws, but I recall telling him that if [he] 25 was not involved in any criminal activities I didn't 26 see an issue with him riding motorcycles with club 27 members. I can't recall Officer Sabettini 28 specifically saying that he was a member of any 29 motorcycle club. 30 (Interview Statement of retired Warden Larry Myers dated January 8, 31 2004.) Lajoie described a conversation in which Sabettini -72- 1 asked whether or not it was an issue if he was a 2 member of the Outlaws. I told him that I didn't 3 know of any directives that specifically addressed 4 being involved with a club of that nature and as 5 long as he was not committing any crimes or doing 6 anything wrong, I didn't believe it violated any 7 departmental policies. I told him that it didn't 8 look very good in the eyes of perception when an 9 officer was believed to be a member of any 10 motorcycle group of this nature. At some point he 11 stated that he was no longer a member and I told him 12 that he was better off not associating with anyone 13 from that organization. I would occasionally have 14 conversations with Officer Sabettini in passing 15 where he would state that he was still out of the 16 organization. Officer Sabettini never informed me 17 of how long he was in the organization or if he held 18 any position within the club. Officer Sabettini 19 never spoke of specifics concerning the club with 20 me. 21 (Interview Statement of Major Michael Lajoie dated December 17, 22 2003.) 23 Piscottano's reliance on the Sabettini affidavit thus 24 leaves a number of questions unanswered. It is not clear, for 25 example, whether the information Sabettini "relayed" to Piscottano 26 was simply that membership in the Outlaws posed no problem-- 27 information that may have been either premature (if relayed in 2001) 28 or outdated (if relayed after the warnings given by Lajoie in 2002)- 29 -or whether the relayed information instead included Lajoie's 30 response that "it didn't look very good in the eyes of perception 31 when an officer was believed to be a member of any motorcycle group" 32 such as the Outlaws, advice that could not reasonably be viewed as 33 countenancing such activities. 34 What is clear is that Piscottano stated he received the 35 Sabettini-relayed advice prior to September 2003, and that that 36 advice could not reasonably be viewed as providing Piscottano any 37 solace thereafter. In September 2003, DOC's interview of Piscottano -73- 1 with respect to his Outlaws-related activities was plainly 2 sufficient to alert him that DOC had a negative view of correctional 3 officers' engaging in such activities. In November 2003, Piscottano 4 received the DOC 2003 Report, which detailed law enforcement 5 agencies' information as to widespread criminal activity on the part 6 of the Outlaws national organization and affiliated chapters. That 7 Report also expressly concluded that Piscottano's continued 8 participation in Outlaws events and wearing of Outlaws colors 9 violated Directive 2.17's prohibition against conduct that could 10 reflect negatively on DOC. Finally, at his Loudermill hearing, 11 which was held on November 21, 2003, Piscottano was "warned that as 12 a result of the violations outlined in the DOC Report, []he[] could 13 be subject to discipline, up to and including termination" 14 (Complaint ¶ 20). Given these DOC proceedings beginning in 15 September 2003, no prudent correctional officer could reasonably 16 rely on the information received in 2001 or 2002 to support a belief 17 that Directive 2.17 would not be violated by his continued close 18 association with the Outlaws. 19 Yet, after his DOC interview in September 2003, Piscottano 20 was identified as one of those who, wearing Outlaws colors, was 21 involved in the October 2003 public altercation with members of 22 another motorcycle club at Chaser's Café, during which Kight was 23 injured and gunshots were fired (see Parts I.C.1. and I.C.2. above). 24 And after receiving the DOC 2003 Report and being warned at his 25 Loudermill hearing in November 2003 that his continued association 26 with the Outlaws could result in his dismissal, Piscottano proceeded 27 to attend the Outlaws Christmas party, wearing Outlaws colors, in -74- 1 December 2003. No rational factfinder could find that Piscottano 2 lacked notice after September 2003 that such conduct could reflect 3 negatively on DOC, in violation of Directive 2.17. The summary 4 dismissal of his vagueness claim was appropriate. 5 3. The July 2004 Conduct of Vincenzo 6 Unlike Kight and Piscottano, who were dismissed in April 7 2004 because of their conduct in the fall and winter of 2003, 8 Vincenzo was not dismissed until late 2004. In connection with his 9 first Loudermill hearing in late 2003, Vincenzo stated that he had 10 not attended any Outlaws event since September 2003, and SD saw no 11 evidence to contradict that representation. Hence, in April 2004, 12 DOC merely ordered that he receive counseling. 13 Vincenzo was dismissed in November 2004, however, 14 following a further Loudermill hearing. The basis for his dismissal 15 was that, after an inquiry to Lantz as to whether Vincenzo's 16 attendance at the July 11, 2004 Outlaws event at the AmVets hall 17 would violate any DOC regulation, and after Vincenzo received a 18 response from Lantz that his attendance at that event would violate 19 Directive 2.17, Vincenzo concededly went to the AmVets hall prior to 20 the scheduled conclusion of the event. He remained there and drank 21 with members of the Outlaws until the end of the event. He departed 22 with members of the Outlaws after the event ended, having donned an 23 Outlaws Support shirt. (See Part I.C.6. above.) 24 Vincenzo's contention that his conduct did not constitute 25 "attend[ance]" at the July 11 event is frivolous, and it is 26 incontrovertible that he received fair notice that his conduct would -75- 1 violate Directive 2.17. His vagueness claim was properly dismissed. 2 4. The Vagueness Claim of Scappini 3 Finally, we find no error in the dismissal of the 4 vagueness challenge by Scappini, but for a different reason. 5 Scappini, unlike the other plaintiffs, apparently did not 6 participate in any Outlaws-related activities after being 7 interviewed by SD in September 2003 or after receiving the DOC 8 Report describing the criminal activities of the OMC. Indeed, the 9 SD 2004 Report on Scappini stated that SD had no information that 10 Scappini had attended any Outlaws event after May 24, 2003. 11 Accordingly, the record does not reveal any Outlaws-related conduct 12 by Scappini after he learned of DOC's concern that such activities 13 would violate Directive 2.17's prohibition against conduct that 14 could reflect negatively on DOC. 15 However, unlike the other plaintiffs, Scappini was not 16 dismissed. He was placed on administrative leave during the 17 pendency of his Loudermill hearing; but that was a fully-paid leave. 18 He was issued a formal counseling letter; but that letter merely 19 advised him that he would be disciplined if he again engaged in the 20 conduct for which he was criticized in the DOC 2003 Report. 21 Scappini suffered no loss of employment, no demotion, no loss of 22 salary, no loss of benefits. In short, Scappini adduced no evidence 23 that the application of Directive 2.17 to him deprived him of any 24 property. His due process challenge to Directive 2.17 was properly 25 dismissed. -76- 1 CONCLUSION 2 We have considered all of plaintiffs' arguments on this 3 appeal and have found them to be without merit. The judgment 4 dismissing the Complaint is affirmed. -77-