Campos v. Cook County

Summary

Public employee's substantive due process claim over eight-year termination proceedings fails because employment rights are not fundamental and the employee did not allege arbitrary or outrageous conduct or inadequate state remedies, as he successfully challenged termination decisions in state court. Conspiracy claims under § 1983 are derivative and cannot stand without an underlying constitutional violation. The district court's dismissal with prejudice is affirmed.

Holdings

1. Campos did not state a substantive due process claim because he did not allege an independent constitutional violation and state remedies were not inadequate; the lengthy process was not arbitrary or outrageous.
2. The district court did not abuse its discretion because Campos failed to state a claim and amendment would be futile.

Questions Presented

1. Whether Campos stated a substantive due process claim based on the protracted termination proceedings.
2. Whether the district court abused its discretion in dismissing the complaint with prejudice.

Disposition

affirmed