David Wilson, an elected trustee of the Houston Community College System, frequently criticized the board and challenged its actions. After the board publicly censured him and imposed related penalties, Wilson sued under the First Amendment. The Supreme Court held that the board’s verbal censure did not violate the Constitution. A governmental body may express its disapproval of an elected member’s speech without imposing a legally cognizable injury, so long as it does not restrict the member’s ability to speak or otherwise penalize protected expression. The Court distinguished cases involving censures accompanied by concrete punishment or retaliation. Because Wilson alleged only a purely verbal reprimand and no loss of a legal right, he lacked a viable First Amendment claim. The Court reversed the Fifth Circuit’s judgment and rejected the argument that the censure itself was an actionable government sanction.