However, not "every person who suffers harm traceable to procedurally questionable government actions" has a valid due process claim. Manley v. Law , 889 F.3d 885, 890 (7th Cir. 2018). To establish a due process violation, a plaintiff must actually have been deprived of a liberty or property interest entitled to constitutional protection.

"To establish a violation, the plaintiff must show that he or she was deprived of a liberty or property interest at issue in the case." Manley v. Law , 889 F.3d 885, 890 (7th Cir. 2018). The plaintiff must also show that he was deprived of that interest without due process.

In their motion for summary judgment, Defendants argue, in part, that Defendants' failure to follow internal policies is not sufficient to state a due process claim. Manley v. Law, 889 F.3d 885, 893 (7th Cir. 2018); Mann v. Vogel, 707 F.3d 872, 882 (7th Cir. 2013); Shango v. Jurich, 681 F.2d 1091, 1101-01 (7th Cir. 1982). In Manley, the court noted that "[e]ven when required by statute or ordinance, purely procedural rules of state and local law give rise to constitutionally protected interests only when the mandated procedure contains within it a substantive liberty or property interest."

Manley v. Law, 889 F.3d 885,893 (7th Cir. 2018).

(citing cases). “If a statute or regulation merely delimits what procedures must be followed before an employee is fired, then it does not contain the requisite substantive procedure.” Cain, 879 F.2d at 1426 (citing Bishop, 426 U.S. at 347; Roth, 408 U.S. at 578); see Manley v. Law, 889 F.3d 885, 893 (7th Cir. 2018) (“For example, a government promise that an employee can be fired only for good cause creates a substantive property right in secure employment, whether or not the government provides procedures to enforce that right.” (citing Swarthout v. Cooke, 562 U.S. 216, 221-22 (2011))). “In other words, the federal Constitution does not enforce compliance with state procedural rules.”

And the interest itself must be "substantive rather than procedural in nature." Manley v. Law, 889 F.3d 885, 890 (7th Cir. 2018).

"To establish a violation, the plaintiff must show that he or she was deprived of a liberty or property interest at issue in the case." Manley v. Law, 889 F.3d 885, 890 (7th Cir.), reh'g denied (June 8, 2018). The Court further reviewed that, in order to establish a liberty interest based on damage to reputation, a plaintiff must establish more than just that; damage to reputation alone is not a protectable liberty interest in and of itself.

Booker-El, 668 F.3d at 900; see Manley v. Law, 889 F.3d 885, 890 (7th Cir. 2018) (substantive interest can be found in "federal positive law" and "must be a freestanding entitlement").

Manley v. Law, 889 F.3d 885, 890 (7th Cir. 2018) (citing Carey v. Piphus, 435 U.S. 247, 263-64, 266 (1978)). Burnett may also seek punitive damages, because, as he states in his appellate brief, Thompson promised to convict Burnett "with or with[ou]t evidence," and this allegation, if true, could allow a jury to find that Thompson acted with an "evil motive" or "reckless or callous indifference" to Burnett's procedural rights, a condition of punitive damages.

See Manley v. Law, 889 F.3d 885, 890 (7th Cir. 2018) ("Procedural due process does not protect every conceivable legal interest.").