Chrebet v. County of Nassau, 24 F. Supp. 3d 236

Chrebet owned Chrebet's Inc. and served as its president; he had a consulting agreement with Prince.
Prince was alleged to have controlled Chrebet's operations; plaintiff claimed Prince’s involvement harmed business.
June 14–15, 2007: fire marshal and police conducted overcrowding/permit checks, with contested counts and licensing postings.
June 21–22, 2007: Soto cited license posting issues and arrested Prince on an open warrant; Prince was a central figure in enforcement actions.
March 2008 raids and meetings involved Fitzgerald, Rothenberg, Szymanski, and others; discussions referenced Prince and his role.
Chrebet’s closed in August 2008; plaintiff later sought damages and brought §1983 and state-law claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Chrebet had a protectable property interest	Chrebet asserts ownership and business interests were deprived.	No cognizable property interest in the business or future profits.	No protectable property interest established.
Whether Chrebet had a protectable interest in his relationship with Prince	Employer had a direct, independent property interest in continued relationship.	No such protected interest; contract allowed termination; no standing to sue for independent relationship.	No genuine issue of fact; no protectable interest.
Whether reputational loss constitutes stigma plus due process	Loss of reputation plus actions reduced his rights and business standing.	No false, actionable statement proven; stigma alone insufficient.	Stigma-plus claim failed; no due process violation.
Whether federal due process and parallel state claims were viable	Due process rights under federal and state constitutions were violated.	No federal due process violation; parallel NY claim also fails.	Both federal and state due process claims dismissed.
Whether supervisory/municipal liability could be established	Supervisory/municipal liability for widespread enforcement actions.	No underlying constitutional violation; no Monell/supervisor liability.	Claims dismissed.

Bd. of Regents of State Colleges v. Roth, 408 U.S. 564 (1972) (property interests defined by state/independent sources)
College Savings Bank v. Florida Prepaid Postsecondary Educ. Expense Bd., 527 U.S. 666 (1999) (business/assets not guaranteed as property; due process limits)
San Jacinto Savings & Loan v. Kacal, 928 F.2d 697 (5th Cir.1991) (lost profits as measure of damages; due process context)
Evac, LLC v. Pataki, 89 F. Supp. 2d 250 (N.D.N.Y.2000) (non-constitutional harms to business operations discussed)
Stein v. Bd. of the City of N.Y., Bureau of Pupil Transp., 792 F.2d 13 (2d Cir.1986) (properties/entitlements derived from independent sources)
Sadallah v. City of Utica, 383 F.3d 34 (2d Cir.2004) (defamation vs. stigma-plus due process distinction)
Patterson v. City of Utica, 370 F.3d 322 (2d Cir.2004) (stigma-plus framework for due process claims)
Kronos v. AVX Corp., 81 N.Y.2d 90 (1993) (injury accrual for tort claims under NY law)
Doe v. Dept. of Pub. Safety ex rel. Lee, 271 F.3d 38 (2d Cir.2001) (false statements and due process implications in stigma context)