The following excerpt is from Tooly v. Schwaller, 919 F.3d 165 (2nd Cir. 2019):
A procedural due process claim requires the plaintiff to establish (1) possession by the plaintiff of a protected liberty or property interest, and (2) deprivation of that interest without constitutionally adequate process. See OConnor v. Pierson , 426 F.3d 187, 195-96 (2d Cir. 2005). Tooly claims that he was twice deprived of a protected property interest: first, when he was placed on involuntary leave in May 2011 and, second, when his employment was terminated in August 2011. The district court did not distinguish between the two deprivationstermination and involuntary leaveand simply found that Tooly had a protected property interest in his continued employment.
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