Quinn v. Syracuse Model Neighborhood Corp.
613 F.2d 438 · Court of Appeals for the Second Circuit · 1980
Facts
Leo Quinn, Rehabilitation Director of a city-funded corporation, was dismissed after city officials publicly implicated him in missing funds and threatened to cut funding if he wasn't fired, despite a grand jury later clearing him. Quinn sued under §1983, alleging deprivation of liberty and property without due process, but the district court granted summary judgment to the defendants. The case was appealed to the Second Circuit.
Issue
Did the district court err in granting summary judgment on Quinn's liberty interest claim, considering evidence of public stigmatization by city officials? Did Quinn possess a protected property interest in his employment, and can the City be held liable under §1983 for the actions of its high-ranking officials?
Holding
The court reversed summary judgment on Quinn's liberty interest claim, finding sufficient evidence of public stigmatization by city officials to preclude dismissal. It affirmed summary judgment on the property interest claim, as New York law did not establish a tenured employment right. The court also held that the City could be liable if the Mayor directed the stigmatizing campaign and that a three-year statute of limitations applies to §1983 claims against municipalities.
Rule
Summary judgment is improper if genuine material facts are disputed, and a liberty interest is implicated when a governmental entity publicly disseminates false, stigmatizing information that harms one's reputation and employment prospects. Municipalities are liable under §1983 for constitutional deprivations caused by official policy, including acts of high-ranking officials, and New York's three-year statute of limitations applies to such claims.
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