With no explanation, chose the best option from "A", "B", "C" or "D". protected ... freedom of speech even if he has no entitlement to that benefit. Bd. of County Comm’rs v. Umbehr, 518 U.S. 668, 674, 116 S.Ct. 2342, 135 L.Ed.2d 843 (1996) (internal quotation marks and citation omitted) (alterations in original). Umbehr involved a § 1983 claim for unlawful retaliation brought against the county’s governing body by an independent contractor who provided trash collection services to the county. The Court held that the contractor had stated a cause of action based on the allegation that his contract was terminated in retaliation for his criticism of the county commission. Umbehr is an extension of the protections provided to public employees under the First Amendment. See Pickering v. Bd. of Educ., 391 U.S. 563, 88 S.Ct. 1731, 20 L.Ed.2d 811 (1968) (<HOLDING>). We believe that the Supreme Court’s rulings

A: holding that the board did not abuse its discretion by dismissing an untimely appeal where the appellant failed to respond to a board order to show cause
B: holding that issues involving the local board of education were matters of public importance
C: holding that members of the board of trustees of an elementary school had standing to challenge the actions of the county board of education because they suffered an actual injury when the county board nullified their unanimous vote to reject a candidate for principal of the elementary school
D: holding that the board of education violated a school teachers first amendment rights by dismissing him because he had criticized the board in a letter to the local newspaper
D.