Bovee v. Broom

Plaintiff failed to state viable section 1983 action alleging that defendant violated his due process rights when defendant, in her capacity as school guidance counselor, criticized plaintiff’s parenting methods and called him “bad father.” Plaintiff essentially asserted defamation action, which, under Paul, 424 US 693, is insufficient to state viable due process violation where, as here, there was no other alleged official action taken by defendant.