Thus, the Chalkboard analysis is incomplete in cases like this one where the plaintiff has an available state law contract claim that might remedy its deprivation. FamilyCare also cites Lantz v. Crate, 268 F. App'x 548 (9th Cir. 2008). There, plaintiffs alleged that members of a Nevada licensing board deprived plaintiffs of their business goodwill when defendants called credit bureaus to report that plaintiffs were violating state law.
There is no indication that the graduation denial has stigmatized Zavareh in any material way. See Constantineau, 400 U.S. at 434-35 (finding stigma where police posted plaintiff's name on list that prohibited her from purchasing alcohol); Paul, 424 U.S. at 695 (defendant posted flyers naming plaintiff as a shoplifter); Lantz v. Crate, 268 F. App'x 548 (9th Cir. 2008) (defendant directly informed credit bureau that plaintiffs were operating their business in violation of state law); Miller v. Cal., 355 F.3d 1172, 1178 (9th Cir. 2004) (plaintiff named as suspected child abuser). Second, even if Zavareh had established stigma, she does not sufficiently plead the necessary "plus" component.