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Free Speech

FA with "FAFO" and FO

Eugene Volokh | 9.21.2026 11:54 AM

A short excerpt from the long opinion in Barlow v. Dep't of Navy, decided Sept. 11 by Merit Systems Protection Board Administrative Judge Scott Borrowman:

On October 29, 2025, shortly after the appellant returned from [a 14-day suspension for "Failure to Enter Accurate Time & Attendance, Lack of Candor, and Disrespectful Conduct"] the suspension, Alger [the appellant's second-level supervisor] noticed a picture of a "red wolf" in the office across the hallway, and when he looked at it, the picture had the text: "After giving it careful thought, I have decided to become worse." When he turned around, he noticed "various writing" on the whiteboard that "in the past had been sterile." Alger indicated the wall was previously bare.

Alger took a picture of the wolf poster. He also took a picture of the whiteboard in the appellant's office. In the upper left corner is the following text: "get fired, get in trouble, be brave, never stop fighting!" There is what appears to be a printout with the following text: "Behold the field in which I grow my fucks. Lay thine eyes upon it and thou shalt see that it is barren."

In the middle-consuming around 70% of the surface-is written: "FAFO!" The initial F has the word "fuck" written many times—Alger counted 25—mingled with scribbles…. The A includes "around" several times. The second F has the word........

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