Redd v. Nolan, 663 F.3d 287

Redd, a Cook County DOC probationary officer, resigned within her 12‑month probationary period (end date November 13, 2007).
She had been a witness in a criminal investigation and refused to lie, leading Detective Dougherty to pressure her for statements.
Dougherty's claim of tortious interference with a business relationship against him was dismissed at the Rule 12(b)(6) stage; remaining claims were litigated against the County.
A county internal investigation led by Detective Velez found multiple violations by Redd and recommended termination; Redd resigned after being advised she would be discharged otherwise.
The Sheriff and related county officials eventually concurred with the recommendation of termination; Nolan advised resignation on October 31, 2007.
Redd pursued First Amendment retaliation, retaliatory discharge, and procedural due process claims, which the district court addressed via summary judgment for the County.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dougherty is liable for tortious interference	Dougherty conspired with Weber to interfere with Redd's employment.	Weber alone filed the complaint; insufficient evidence of Dougherty's involvement.	Dougherty's claim dismissed
Whether the First Amendment retaliation and retaliatory discharge claims survive	Redd was terminated in retaliation for refusing to lie to prosecutors.	No plausible evidence showing retaliatory motive; Velez’s investigation did not target Redd for protected activity.	Summary judgment for County; no triable issue on retaliation
Whether Redd had a protected due process property interest in probationary employment	DOC rules and the 'terminate for cause' language created a protected interest.	Probationary employees can be summarily terminated; no clear policy statement altering at-will status.	No protected property interest; due process claim fails

Windy City Metal Fabricators & Supply, Inc. v. CIT Tech. Fin. Servs., 536 F.3d 663 (7th Cir. 2008) (pleading standards require enough facts to raise reasonable expectation of relief)
Tamayo v. Blagojevich, 526 F.3d 1074 (7th Cir. 2008) (Twombly pleading standard applies; complaint need not show probable success)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plaintiff must plead plausible grounds for relief)
Border v. City of Crystal Lake, 75 F.3d 270 (7th Cir. 1996) (procedural protections do not create federally protected property interests)
Lashbrook v. Oerkfitz, 65 F.3d 1339 (7th Cir. 1995) (contractual language signaling termination for cause does not create guaranteed for-cause discharge)
Moss v. Martin, 473 F.3d 694 (7th Cir. 2007) (permissive 'may be discharged for cause' language does not guarantee due process protection)
Boulay v. Impell Corp., 939 F.2d 480 (7th Cir. 1991) (no implied 'just cause' in probationary termination language)