O'Donnell, Philip v. Barry, Marion S.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a deputy chief in the D.C. police department who was demoted and later obtained a position as a police chief of a small town of 6000 failed, as a matter of law, to demonstrate deprivation of a liberty interest under a “stigma” analysis
• holding the request for a name-clearing hearing need not be explicit, but must be “reasonably clear”
• explaining that plaintiffs must demonstrate “the combination of an adverse employment action and ‘a stigma or other disability that foreclosed [the plaintiff’s] freedom to take advantage of other employment opportunities’”
• noting that “defamation alone is not actionable under the due process clause, but that defamation ‘in the course of the termination of employment’ is” (quoting Paul v. Davis, 424 U.S. 693, 710, 96 S.Ct. 1155, 47 L.Ed.2d 405 (1976))
• finding no “reputation-plus” harm where plaintiff pointed only to “isolated defamatory statements and to a demotion” without “demontrat[ing] that the two occurred together”
• declining to find a liberty interest claim where police officer complained about defamatory public statements, but there was no evidence that the public statements accompanied the adverse employment action.

Source: CourtListener parenthetical corpus (CC0).