After reviewing the record and the briefs in this case, we agree with the district court — for the reasons stated in its September 8, 2005 order granting summary judgment — -that Mr. Smith would have been demoted for insubordination notwithstanding the email he wrote on May 16, 2002, as president of the Chatham County Fire Chiefs Association, and that *99Mr. Brown is entitled to qualified immunity-

AFFIRMED.