Senra v. Town of Smithfield, No. 12-1600 (1st Cir. 2013)
Annotate this CaseAppellant was a probationary public employee of the Town of Smithfield, Rhode Island. The Town hired Appellant on the condition that he obtain his building official certification. After Appellant failed to obtain the certification, the Town terminated Appellant. Appellant filed a complaint against the Town and its officials, alleging that he received insufficient procedural due process in violation of the Fourteenth Amendment when his employment was terminated and that the Town violated the Rhode Island Constitution and Rhode Island Whistleblowers' Protection Act when it fired him. Defendants removed the case to federal court. The district court granted Defendants' motion for summary judgment on all counts. The First Circuit Court of Appeals affirmed, holding (1) Appellant received constitutionally adequate procedural due process; and (2) the district court acted within its discretion in reaching and resolving the state law claims after ruling against Appellant on the sole federal claim.
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