"[A] person's good name, reputation, honor, and integrity are among the liberty interests protected by the due process clause of the Fourteenth Amendment." Chilingirian v. Boris, 882 F.2d 200, 205 (6th Cir. 1989); Bessent v. Dyersburg State Community College, 224 Fed. Appx. 476, 480 (6th Cir. 2007). Defamation alone, however, is insufficient to invoke due process concerns.
" Quinn, 293 F.3d at 319 (emphasis added) (quoting Paul, 424 U.S. at 711-12); see Crosby, 863 F.3d at 555 ("[D]efamation alone is not enough to trigger this constitutional protection; rather, the alleged damage must be tied to '[s]ome alteration of a right or status previously recognized by state law.'" (second alteration in original) (quoting Quinn, 293 F.3d at 319)); Bessent v. Dyersburg State Cmty. Coll., 224 F. App'x 476, 480 (6th Cir. 2007) ("Some alteration of a right or status 'previously recognized by state law,' such as employment, must accompany [the] damage to reputation." (quoting Quinn, 293 F.3d at 319)); Satkowiak v. Bay Cty. Sheriff's Dep't, 47 F. App'x 376, 379 (6th Cir. 2002) ("[M]ore is required than simply a state-imposed stigma[;] there must be a state-imposed stigma as well as a corresponding loss of right or status.
For example, we did not find stigma when an administrator at a non-profit was terminated because there "'were some recurring problems with the management of the grant'" as well as "'some basic policies that weren't being followed.'" Bessent v. Dyserburg State Cmty. Coll., 224 F. App'x 476, 480 (6th Cir. 2007). Despite the employee's claims in that case that "several friends contacted her and said that it sounded like she had stolen money," we held that such comments imposed no stigma of dishonesty or immorality, but rather spoke only of inadequate job performance.
Further, with respect to their right to reputation, Plaintiffs must establish that the Defendants made false, stigmatizing statements about them. Bessent v. Dyersburg State Community College, 224 Fed. Appx. 476, 480 (6th Cir. 2007). No such allegations have been made in the instant case, and therefore Plaintiffs cannot maintain a substantive due process violation based upon alleged infringement on their liberty interest in their respective reputations.
The Court nonetheless noted that the inquiry is "a practical one," and the Sixth Circuit's recent cases addressing Garcetti provide some guidance. Id.; see Haynes v. City of Circleville, 474 F.3d 357, 365 (6th Cir. 2007); Bessent v. Dyersburg State Cmty. Coll., No. 06-5305, 2007 WL 959420 (6th Cir. Apr. 2, 2007); Ibarra v. Lexington-Fayette Urban Co. Gov't, No. 06-5671, 2007 WL 579670 (6th Cir. Feb. 23, 2007).