Whether debarment from government work implicates a government contractor's liberty interest for purposes of the stigma-plus test

QUESTION PRESENTED In Board of Regents of State Colleges v. Roth, this Court held that the government impinges on a government employee’s constitutional liberty interests when, in terminating the employee, the government “imposed on him a stigma or other disability that foreclosed his freedom to take advantage of other employment opportunities.” 408 U.S. 564, 573 (1972). Not long after, in Paul v. Davis, the Court held that to make out a due process claim for deprivation of a liberty interest, a plaintiff must show a stigma to his reputation plus deprivation of some additional right or interest. 424 U.S. 693, 701 (1976). In the decades since, courts have widely interpreted Roth and Paul as creating a “stigma-plus” test for establishing a constitutional liberty deprivation. The Question Presented is: Whether debarment from government work implicates a government contractor’s liberty interest for purposes of the stigma-plus test, as the D.C., Second, Fifth, Sixth, Eighth, and Federal Circuits have held, or whether a government contractor must instead meet some higher standard, as the Seventh, Ninth, Tenth, and Eleventh Circuits have held.