Goetz v. Windsor Central School District
Second Circuit
698 F.2d 606 (2d Cir. 1983)
At-will school cleaner Dennis Goetz (plaintiff), entitled under a collective-bargaining agreement to notice and an explanation before termination, was suspended after being arrested and charged with burglary connected to a series of office thefts at Windsor Central School District (defendant); the district asked him for a written explanation of his involvement, which he never provided, and instead sent a letter alleging his suspension without a hearing was unconstitutional and demanding one. The district then fired him for failing to provide the requested written explanation, while separately circulating an internal memo demanding strict confidentiality about "recent events"; Goetz sued alleging deprivation of property and liberty interests under the Fourteenth Amendment, and the district court granted the district summary judgment, which Goetz appealed.
Whether an at-will employee's contractual entitlement to notice and an explanation before termination creates a constitutionally protected property interest in continued employment.