The image of public university professors shackled as pawns of the state is repugnant to the American concept of a democratic free society. Without protection for academic freedom, however, such an image could represent the future role of professors at public universities. The law in this area has been in disarray for years, and although the Supreme Court has extolled the virtues of First Amendment academic freedom rights for both professors and universities, it has provided no explicit mechanism for deciding these cases. Confusion among lower courts and commentators as to the nature of these rights recently culminated in the Fourth Circuit's categorical denial of constitutional academic freedom to professors in Urofsky v. Gilmore. The clearly incorrect result in Urofsky makes more imperative than ever careful clarification of the proper approach to cases involving claims of constitutional academic freedom. This Comment argues that the confusion is unnecessary because, although the Court has not given explicit guidance, its public employee jurisprudence provides all of the tools lower courts need to decide these important cases. Because academic speech is made by public employees within public institutions and is thus subject to the state's managerial power, this Comment advocates applying a reformulated public employee framework. Specifically, courts should utilize a functional necessity test when deciding public university professors' academic freedom claims. This Comment analyzes already decided cases against this backdrop, demonstrating that although courts purport to be operating under different frameworks, similar analysis goes on behind the scenes: courts protect professorial academic freedom rights when restriction of academic expression is not functionally necessary to the state's legitimate goals. In fact, where the state's goals are critical democratic education or the promotion of new discoveries, academic freedom is not a hindrance but rather is crucial to the accomplishment of the state's mission. Approaching constitutional academic freedom in this way eliminates the need to distinguish between individual and institutional rights in situations like those presented in Urofsky, and demonstrates that the Urofsky court should not have categorically denied such freedom to professors. Unlike the Urofsky court's analysis of academic freedom rights, the framework outlined in this Comment is specifically motivated by the values the Supreme Court has advanced in its discussions of both academic freedom and public employee speech rights and protects more expression than alternative approaches do.