Snepp v. United States
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|Snepp v. United States|
|Court||Supreme Court of the United States|
|Date decided||February 19, 1980|
|Appealed from||4th Circuit|
As a condition of employment, FRANK SNEPP signed an agreement to not disclose classified information during or after his service without prior restraint. After leaving the CIA, Snepp published Decent Interval (1977) without seeking prior approval from the CIA.
The federal government sues Snepp for breach of contract & breach of fiduciary relationship. The government sought the creation of a constructive trust (due to unjust enrichment) to turn over the book's royalties to the government instead of the author Snepp.
An employment contract requiring employees to submit their publications for prior review do not violate public employees’ free expression rights under the 1st Amendment.