Carmody v. Bd. of Trustees of the University of Illinois

Dist. Ct. erred in dismissing portion of plaintiff-university employee’s claim alleging that defendant-university violated his rights under Due Process Clause when it terminated him for alleged security breach involving university’s email system without conducting sufficient pre-termination hearing. Instant breach concerned plaintiff’s possession of certain emails that plaintiff had used in unrelated state court action against another university employee, and although defendant met with plaintiff on one occasion before his termination to discuss charges against him, plaintiff sufficiently alleged due process violation where he claimed that his termination came before he had opportunity to explain his possession of said emails, where state court had entered order at time of said pre-termination meeting directing defendant and others not to discuss subject matter of emails.