(November 5, 2015, 11:22 AM EST) -- ATLANTA — A memorandum authored by five university employees accusing their supervisor of mismanagement and poor leadership was not speech protected by the U.S. Constitution, a split 11th Circuit U.S. Court of Appeals panel ruled Oct. 29, affirming a trial court’s decision (Melissa A. Alves, et al. v. Board of Regents of the University System of Georgia, et al., No. 14-14149, 11th Cir.; 2015 U.S. App. LEXIS 18802)....