Julia Correia v. Glenn Jones, 943 F.3d 845

Correia was Coordinator of the Center for Language Proficiency and an ESL instructor at Henderson State University; her fixed-term employment contract for 2013–2014 expired June 30, 2014 and was not renewed.
Henderson’s Board included Correia’s position in the proposed 2014–2015 budget, but no renewed contract was executed.
After a whistleblower tip and an unofficial review, the Arkansas Legislative Joint Auditing Committee (LJAC) conducted a formal audit of the Center; Correia was placed on paid administrative leave July 7, 2014, and the Center closed October 3, 2014.
The LJAC audit report became public December 16, 2014; President Jones emailed staff attaching the report and local news articles quoted Jones regarding the audit (the report was prepared independently by LJAC).
Correia requested a name‑clearing hearing on August 15, 2017 and sued Jones under 42 U.S.C. § 1983 and the Arkansas Civil Rights Act on August 22, 2017; the district court granted Jones summary judgment based on qualified immunity and dismissed state claims without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Correia had a property interest in continued employment (due‑process right)	Inclusion of her salary/position in the Board budget and past year‑to‑year contracts created an entitlement to continued employment for 2014–2015	No renewed fixed‑term contract existed; Arkansas law presumes at‑will employment absent a fixed term or handbook provision limiting discharge	Held: No property interest; budget inclusion did not create a contract and Correia was at‑will
Whether Correia had a protected liberty interest (right to a name‑clearing hearing)	Jones’ email attaching the audit and public comments disseminated a defamatory/stigmatizing impression linking her to misuse/mismanagement, triggering a name‑clearing hearing	The audit and articles (independently produced) did not contain direct accusations by Jones; his email made no specific dishonesty/criminality allegations about Correia	Held: No liberty interest deprivation; no evidence Jones made direct stigmatizing, defamatory statements requiring a name‑clearing hearing

Bd. of Regents v. Roth, 408 U.S. 564 (establishes property‑interest/entitlement standard for benefits)
Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (due‑process principles for deprivation of property in public employment)
Eddings v. City of Hot Springs, 323 F.3d 596 (Arkansas law: employment at‑will unless fixed term or handbook limits discharge)
Floyd–Gimon v. Univ. of Ark. for Med. Sci., 716 F.3d 1141 (property‑interest inquiry depends on state law)
Mogard v. City of Milbank, 932 F.3d 1184 (qualified immunity framework and stigma/liberty‑interest analysis)
Malcak v. Westchester Park Dist., 754 F.2d 239 (inclusion in budget does not create year‑to‑year employment contract)
Crews v. Monarch Fire Prot. Dist., 771 F.3d 1085 (stigma exception requires direct allegations of dishonesty/immorality/criminality)
Hogue v. Clinton, 791 F.2d 1318 (unilateral expectation of continued employment insufficient for due‑process protection)