Peterson v. Johnson, No. 23-3338 (6th Cir. 2023)
Annotate this CaseBradley Peterson, a former professor at Ohio State University, claimed his procedural-due-process rights were violated when the university stripped him of his emeritus status without adequate process. Following a sexual harassment complaint against him, the university conducted an investigation, concluded that Peterson violated the university's Sexual Misconduct Policy, and subsequently revoked his emeritus status. Peterson argued that he had a property interest in his emeritus status and its related benefits. The United States Court of Appeals for the Sixth Circuit, however, affirmed the district court's decision to dismiss Peterson's complaint. The court held that Peterson failed to establish a constitutionally protected property interest in his emeritus status. The court noted that emeritus status was an honorific title, and Peterson did not show that he lost pay or tangible benefits from Ohio State when his emeritus status was revoked. The court also noted that Peterson's claim of harm to his professional reputation was akin to a liberty interest claim, and he did not request a name-clearing hearing, which was a prerequisite for asserting such a claim.
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