The following excerpt is from Autotech Collision Inc. v. Inc., No. 15-4187-cv (2nd Cir. 2016):
To pursue a substantive due process claim, plaintiffs must show egregious, outrageous government conduct injurious to an interest implicit in the concept of ordered liberty. See, e.g., Velez v. Levy, 401 F.3d 75, 93 (2d Cir. 2005). Plaintiffs' substantive due process claim fails because they do not allege any such interest. To the extent they complain of being denied "the award of the towing contract," J.A. 241, New York law
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