Whether, in a retaliation case, to overcome qualified immunity a plaintiff need only establish that the right retaliated against was clearly established, or instead, as the Tenth Circuit held, the plaintiff must establish that both that the right retaliated against was clearly established and that it was clearly established that government officials are forbidden from retaliating against that specific right in the specific manner used in the plaintiff's case.

Whether a plaintiff must establish both that a constitutional right was clearly established and that the specific manner of retaliation was clearly unconstitutional in order to overcome qualified immunity in a First Amendment retaliation case