Hannemann v. Southern Door County School District, 673 F.3d 746

Derek Hannemann, a nonstudent at the time, was banned from Southern Door County School District property indefinitely after multiple incidents in 2007 and 2008.
Initially, Hannemann was suspended and later expelled in 2006-2007 for knife possession and subsequent misconduct; the expulsion was later reversed by the state superintendent, but Hannemann did not reenroll.
In 2008 Hannemann was prohibited from entering school grounds after a weight-room incident, without notice or a hearing, leading to a trespass citation when he later returned.
Hannemann sued under § 1983 alleging violations of procedural due process, liberty interests, and intrastate travel, naming the district and administrators in their individual capacities.
The district court granted summary judgment on all claims; on appeal Hannemann challenged only the ban from school property and its due process implications.
The Seventh Circuit held Hannemann has no protected liberty interest as a member of the public to access school grounds and affirmed summary judgment for the defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the indefinite ban from school grounds violate a protected liberty interest?	Hannemann argues a public-liberty interest is implicated by the ban.	District contends no protected interest exists for non-students accessing school grounds.	No protected liberty interest; ban不 constitutes due process violation.
Does stigma plus analysis apply to a non-student ban from school property?	Ban harms reputation and alters legal status if publicized.	No defamatory statements or status change proven; waiver and lack of stigma shown.	Waived and, even if considered, stigma-plus not shown.
Does the ban implicate Hannemann's intrastate-travel rights?	Ban infringes on travel to access public facilities.	Right to intrastate travel does not guarantee access to every public place.	No violation of intrastate-travel rights.
Are the individual defendants entitled to qualified immunity on the ban claim?	Qualified immunity should not shield ongoing due-process denial.	Even if no constitutional violation, law was not clearly established; immunity applies.	Qualified immunity provides alternative basis; claim fails on merits.

Wisconsin v. Constantineau, 400 U.S. 433 (1971) (stigmatic harm requires concrete form and is not automatic)
Paul v. Davis, 424 U.S. 693 (1976) (stigma plus framework; defamation plus loss of status required)
Bd. of Regents of State Colleges v. Roth, 408 U.S. 564 (1972) (range of procedural due process interests not infinite)
McMahon v. Kindlarski, 512 F.3d 983 (7th Cir. 2008) (liberty interests may arise from state law; due process analysis)
Doe v. City of Lafayette, 377 F.3d 757 (7th Cir. 2004) (intrastate travel right not a right to enter every public facility)
City of Chicago v. Morales, 527 U.S. 41 (1999) (loitering dicta; not controlling for access to school grounds)