How have courts interpreted the term "honesty" and "ethics" in the context of an employment claim?

In Tibbetts v. Kulongoski , 567 F.3d 529, 530 (9th Cir. 2009), former employees brought a 1983 action against the Governor of Oregon and other state actors alleging violation of their Fourteenth Amendment due process rights. The employees maintained that the state made stigmatizing statements about them in press releases without providing name-clearing hearings. See id. We reiterated that "a liberty interest is implicated in the employment termination context if the charge impairs a reputation for honesty or morality." Id. at 535 (citation omitted). We concluded that statements referencing "strengthening accountability and transparency," "ethics," "honesty," and "openness" were "more analogous to cases where honesty ... has been implicated." Id. at 537 (alteration omitted).