Board of Regents (1967). The interest of the teacher as a citizen in making public comments must be balanced with the interest of the State in promoting the efficiency of the public services of its employees. The court found that the applicant's statements were substantially correct, concerned matters of public interest and did not raise issues of discipline or harmony between teachers. The statements offered no adequate basis for the school board's action to fire the appellant (Oyez, n.d.). The court declared that the applicant's statements were false and concerned matters of importance to the public's attention. The statements were neither shown nor could they be presumed to interfere with the appellant's performance of his teaching duties or the operation of the school (Oyez, n.d.). On the issue of misrepresentation, the Supreme Court looked back to New York Times Co. v. Sullivan (1964). The school board was unable to prove that the statements were malicious in nature. The Supreme Court overturned the Illinois Supreme Court's ruling