Christopher Wiles v. Mary Rezac

Summary

The United States District Court for the District of Kansas grants Defendant Mary Rezac’s Rule 12(b)(6) motion to dismiss claims brought by Christopher Wiles concerning the termination of his employment at the University of Kansas. The court concludes that, assuming Wiles had a protected property interest, the pre- and post-termination procedures available under the Kansas Judicial Review Act satisfied due process, and it also addresses qualified and Eleventh Amendment immunity. The court declines supplemental jurisdiction over Wiles’s state-law tortious-interference claim and closes the case.

Holdings

1. Even assuming Wiles possessed a protected property interest in continued employment, he failed to state a procedural due process claim because he received meaningful pre-termination procedures and the Kansas Judicial Review Act provided an adequate opportunity for post-termination review.
2. Rezac was entitled to qualified immunity because Wiles failed to show a constitutional violation, and, in any event, the asserted right to a post-termination hearing separate from judicial review under the Kansas Judicial Review Act was not clearly established.
3. Rezac was immune from Wiles's official-capacity claim because it was effectively a claim against the State and Wiles did not allege an ongoing violation of federal law sufficient to invoke the Ex parte Young exception.
4. The court declined to exercise supplemental jurisdiction over the state-law tortious-interference claim after dismissing all federal claims.

Questions Presented

1. Whether Wiles adequately alleged that he was deprived of procedural due process when his University of Kansas employment was terminated without just cause and without a separate post-termination hearing.
2. Whether Rezac was entitled to qualified immunity on Wiles's individual-capacity due process claim.
3. Whether Rezac was immune under the Eleventh Amendment from Wiles's official-capacity claim.
4. Whether the court should exercise supplemental jurisdiction over Wiles's state-law tortious-interference claim after dismissing all federal claims.

Disposition

dismissed