Biggs v. Chicago Board of Education

Dist. Ct. did not err in granting defendant-employer’s motion for summary judgment in plaintiff-employee’s section 1983 action, alleging that defendant deprived her of her liberty to pursue her occupation as school administrator without due process when it made stigmatizing public statements about her in connection with her termination as interim school principal. Record showed that defendant disclosed reasons for plaintiff’s termination at two community meetings, that plaintiff subsequently searched in summer after her termination for principal positions without success, and that defendant placed “do no rehire” designation in her personnel file. Plaintiff was required to show that defendant’s public statements made it virtually impossible for her to find employment within in her school administrator occupation, and plaintiff failed to make said showing, where: (1) defendant’s designation of “do not rehire” in her personnel file did not qualify as public statement; (2) plaintiff always had ability to apply for school administrator positions in other school districts; (3) plaintiff made applications to only seven other jobs, only one of which was school administrator position, which was insufficient to show that she was excluded from school administrator field; (4) plaintiff’s delay in obtaining any other job was due to normal difficulties of applicants who had been terminated from their prior positions; and (5) plaintiff failed to show that any potential employer was aware of subject public statements, except for one potential employer who interviewed plaintiff anyway.