A Tennessee federal district court granted the Town of Lynnville’s motion to dismiss claims brought under 42 U.S.C. § 1983 for alleged First and Fourteenth Amendment violations by a female town recorder and head of water department who was terminated, finding she had no property interest in her at-will employment, her reputation claims failed the “stigma-plus” test, she failed to show conscience-shocking conduct for substantive due process, and her speech at a board meeting was made pursuant to official duties rather than as a private citizen.
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