Facts

Don Moody filed suit against the County of Santa Clara and Bruce Wagstaff in relation to his placement on administrative leave and termination from his employment with the County of Santa Clara as Public Administrator/Public Guardian in September 2014. In August 2014, Wagstaff and James Ramoni learned that the Public Guardian's office had failed for nine months to implement court orders directing the office to transfer conservatees from locked mental health facilities to less restrictive plaintiffs. On September 25, 2014, Wagstaff and Ramoni informed Moody he was being placed on administrative leave for failure to adequately and effectively perform his job duties to the level expected of an executive manager.

PLAINTIFF'S CONTENTIONS: Moody contended that as he was escorted out of the County building after being placed on administrative leave, other employees saw him exiting the building and informed a reporter that Moody had been placed on leave. Moody contended that he was denied his substantive due process rights because the walkout and defendants' leak of negative information concerning him effectively precluded him from performing future work in his chosen profession. Moody claimed that defendants' acts were arbitrary and capricious such that they shocked the conscience and were causally connected to his difficulty to securing further employment in healthcare.

DEFENDANTS' CONTENTIONS: Defendants denied the allegations and contended that the evidence was insufficient to show that Moody was deprived of his right to pursue a profession.

Result

The court granted defendants' motion for summary judgment. The court found that Moody found employment in the healthcare industry following his termination and his arguments regarding loss of salary or equivalent opportunities did not establish a claim for violation of occupational liberty. As such, the court concluded Moody's claims failed because he did not show complete exclusion from healthcare administration. The court also concluded that Moody did not establish that defendants' leak rose to the level of intentional and malicious fabrication of falsehoods, and the information in the article published was objectively true.