Background - Kando served as executive director (secretary) of the Rhode Island State Board of Elections from 2005 until his termination in August 2016. Conflicts with new Board members led to disciplinary actions in 2016. - In January 2016 the Board rescinded a prior termination decision, suspended Kando without pay for 15 days, and required enrollment in three semesters of management courses; the minutes did not set a concrete enrollment/completion deadline. - A January 19 letter from the Board instructed Kando to begin courses that month and report progress; Kando did enroll at Johnson & Wales but missed the letter’s end-of-January enrollment deadline and was suspended for six weeks. - On August 31, 2016 the Board held a special meeting, did not let Kando speak, and voted to terminate him while he was still completing the coursework. - Kando sued under 42 U.S.C. § 1983, alleging deprivation of due process (loss of employment and a stigmatization/name-clearing claim). The district court granted judgment on the pleadings for defendants; this appeal followed. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---|---| | Whether Kando had a constitutionally protected property interest in continued employment | Kando contends the Board’s January actions/ letter created an enforceable promise or contract entitling him to continued employment while completing required courses | Board argues Kando was an unclassified, at-will employee under Rhode Island law and had no property interest | Held: No protected property interest — unclassified status means at-will employment; Board lacked authority to alter that status | Whether state statutes or doctrines created a term or contractual right | Kando points to statutes and dicta suggesting limited exceptions or implied-contract possibilities (e.g., comparison to other statutory exceptions) | Defendants: cited controlling Rhode Island precedent holding unclassified employees serve at pleasure of appointing authority; no applicable statute gives Board authority to bind employment term | Held: No statutory or recognized state-law basis to convert Kando’s status into a property right | Whether Kando stated a stigmatization (liberty) claim requiring a name-clearing hearing | Kando alleges the Board publicly defamed/tarnished him and denied opportunity to clear his name | Defendants: argue allegations are vague, fail to plead requisite elements (false statements, publication by the government, linkage to termination, request for hearing) | Held: Dismissed — complaint too conclusory; fails to allege publication by Board, connection to termination, and a post-termination request for name-clearing hearing | Pleading sufficiency on § 1983 claims at judgment-on-the-pleadings stage | Kando urges that the complaint’s allegations should be read generously to state plausible § 1983 claims | Defendants maintain allegations are meager, conclusory, and fail required elements for due-process or stigma claims | Held: Judgment on the pleadings affirmed — allegations are conclusory and insufficiently particularized to survive ### Key Cases Cited Bd. of Regents v. Roth, 408 U.S. 564 (1972) (property interest in public employment must be grounded in state law) Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (1985) (procedural due process protections for public employment removal) Bishop v. Wood, 426 U.S. 341 (1976) (property-interest inquiry is by reference to state law) Paul v. Davis, 424 U.S. 693 (1976) (distinction between injury to reputation and deprivation of liberty or property) Codd v. Velger, 429 U.S. 624 (1977) (name-clearing hearing recognized where stigma-plus occurs) Wojcik v. Mass. State Lottery Comm'n, 300 F.3d 92 (1st Cir. 2002) (stigma-plus and public-employee defamation standards) Buntin v. City of Boston, 813 F.3d 401 (1st Cir. 2015) (elements required for a public-employee stigmatization claim) Silva v. Worden, 130 F.3d 26 (1st Cir. 1997) (government publication requirement distinguishes rumors from official defamatory statements) * Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must plead factual matter plausibly suggesting entitlement to relief)