Owen v. City of Independence

Police chief George Owen (plaintiff) was terminated by the city manager of Independence, Missouri, a day after a city council meeting where a councilman publicly accused him of wrongdoing based on an internal investigation report, and the council simultaneously voted to release the report to prosecutors and the press; Owen was given no reason for termination, and an internal appeal was denied without a hearing under the city charter's discretion granted to the city manager. Owen sued the city, city manager, and council members (defendants) for due process violations, and after a remand for reconsideration in light of intervening precedent recognizing municipal liability under § 1983, the court of appeals reaffirmed a constitutional violation but held all defendants, including the city itself, entitled to qualified immunity.