School board member and her husband brought § 1983 action in state court against school district and district superintendent, alleging their handling of investigation of board member’s alleged bullying of student and their public criticism of board member violated her due process rights.
Defendants removed action to federal court. The United States District Court granted summary judgment to district and superintendent. Board member appealed.
The Court of Appeals held that:
- There is no liberty interest, protected by the Due Process Clause, in a feeling that the government has dealt with an individual fairly;
- Board member did not have a protected liberty interest in her emotional well-being upon which she could base her procedural due process claim; and
- District’s and superintendent’s alleged failure to follow school board policy and state procedural law in investigating board member did not constitute a denial of any constitutionally protected liberty interest.