Snowden v. Adams
District Court, C.D. Illinois · 2011-09-01 · cited 2×
In Snowden v. Adams, plaintiff Richard Snowden, former Superintendent of the Illinois School for the Visually Impaired, sued several state Department of Human Services officials under 42 U.S.C. § 1983, alleging that their handling of complaints and public dissemination of information about his lack of credentials and alleged misconduct deprived him of a liberty interest in his occupation without due process. The court granted summary judgment to defendants Hou, Kilbury, Smith, Olson, and Breen, finding insufficient evidence of their personal involvement in the key stigmatizing actions, but denied summary judgment to defendant Adams. The core reasoning was that Adams, as Secretary, was directly involved in receiving and forwarding complaints to a state senator, which could constitute public stigmatization implicating Snowden's liberty interest, and that a name-clearing hearing (or damages if inadequate) is the proper remedy for such a deprivation. The court noted that Snowden had not shown a legal barrier to future employment but focused on the procedural due process claim arising from the stigma-plus-altered-legal-status framework.