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Cleveland Board of Education v. Loudermill

United States Supreme Court
470 U.S. 532 (1985)


Facts

James Loudermill (plaintiff) was employed by the Cleveland Board of Education (Board) (defendant) as a security guard. Loudermill was a classified civil servant, which meant that under Ohio law he could only be terminated for cause, with a right to administrative review if terminated. On his employment application, Loudermill stated that he had never been convicted of a felony. When the Board later discovered that Loudermill had been convicted of a felony, he was terminated for dishonesty in his application. He was not given an opportunity to respond to the charges of dishonesty or to challenge his termination. Loudermill appealed his termination to the Cleveland Civil Service Commission. Loudermill asserted that he believed his prior conviction was a misdemeanor instead of a felony, and a referee recommended reinstating Loudermill, but the commission ultimately upheld Loudermill's dismissal. Loudermill brought suit in federal district court, alleging that the Ohio statute was unconstitutional because it did not allow employees a pre-termination opportunity to respond to charges against them. According to Loudermill, this denied terminated employees of liberty and property without due process. The district court dismissed Loudermill's complaint for failure to state a claim because the Ohio statute that created the property right in continued employment also set forth discharge procedures, and the fact that those procedures were followed in Loudermill's case meant that he was given all the process he was due. The court also found that Loudermill's post-termination hearing was sufficient to protect his liberty interests. The appellate court reversed, concluding that Loudermill's due-process rights had been violated. Although the appellate court agreed with the district court's conclusion about the post-termination hearing, the court held that an employee's interest in retaining employment, plus the value of presenting evidence before the employee's dismissal, outweighed any additional administrative burden of holding a pre-termination hearing. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (White, J.)

Concurrence (Marshall, J.)

Dissent (Rehnquist, J.)

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