Skip to content
A Member of the Law Professor Blogs Network

The dismissal of a state’s attorney employee was affirmed by the United States Court of Appeals for the Fourth Circuit

Barbara Smith was fired from her position with the St. Mary’s County State’s Attorney’s Office. The County warned her ahead of time that she was being investigated for improperly handling confidential information and allowed her to respond to those allegations. It then fired her for conduct related to the alleged improper handling. She appealed that decision. A review board upheld her termination after a two-day hearing. She now argues that the County and the County Sheriff violated her due process rights by failing to provide adequate pre- and post-termination procedures. The district court dismissed her claims, finding the procedures constitutionally adequate. We agree and affirm. The County and Sheriff provided sufficient process to Smith.