Austell, et al. v. Sprenger, et al., No. 11-2792 (8th Cir. 2012)
Annotate this CaseTYBE, a daycare center in St. Louis, Missouri, sued the Missouri Department of Health and Senior Services (DHS), alleging federal civil rights and state law violations because DHS denied TYBE's license renewal request. On appeal, TYBE challenged the district court's grant of summary judgment on its due process claims and its state-law tortious interference claim. The court held that TYBE had not demonstrated that it had a clearly established property interest in renewal of its license and therefore defendants were entitled to qualified immunity. The court also held that, if TYBE had a legitimate claim of entitlement to operate during the revocation review period, this right was not clearly established, and any injury to TYBE's reputation, by itself, would not trigger any protectable liberty interest. Therefore, defendants were entitled to qualified immunity regarding the challenged statements. The court rejected TYBE's claims that defendants deprived it of due process by failing to make an initial settlement offer to TYBE in conjunction with the license denial review proceedings. The court further held that TYBE was not deprived of any due process rights by a DHS employee's motion to dismiss TYBE's complaint. Finally, TYBE's tortious interference claim failed as a matter of law. Accordingly, the court affirmed the judgment.
Court Description: Civil case - Civil Rights. The Department of Human Services defendants could reasonably conclude that the plaintiff child care center had no constitutionally protected property interest in the renewal of its license, and the district court did not err in granting the defendants summary judgment based on qualified immunity; defendants were also entitled to qualified immunity on plaintiffs' claim that defendants' announcement concerning plaintiffs' unlicensed status violated plaintiffs' due process liberty interests; even assuming plaintiffs had a state law right to a settlement offer, there is no constitutionally cognizable interest in the offer itself; defendants were entitled to official immunity on plaintiffs' state law claims for tortious interference with a business expectancy.
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