In
Okemgbo v. Washington State Department of Ecology, (ED WA, Feb. 24, 2014), a Washington federal district court upheld against a First Amendment challenge a state agency's imposing on one of its employees who had authored a book on Christianity and marriage the following work restrictions:
You are not to use your work time for any non-work activity including:
• Promoting and soliciting contributions of money, time or other donations for your non-profit organization or other non-work related activities that you are involved in
• Promoting, selling and/or distributing your book on marriage
• Promoting religious opinions, providing religious information, counseling, offers to pray.
The court concluded that: "the Department’s interest in maintaining a workplace that is free of sexual harassment, does not promote a particular religion, and which maintains some semblance of order and efficiency outweighs the Plaintiff’s interest in selling his book, promoting his religious beliefs, or running his nonprofit organization, while he is supposed to be working."
