Due Process-Employment

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7^th Circuit Court of Appeals

Case Name: Angelique Snowden v. Illinois Department of Human Services

Case No.: 22-1848

Officials: Flaum, Rovner, and St. Eve, Circuit Judges.

Focus: Due Process-Employment

Snowden challenges her discharge from the Illinois Department of Human Services (the “Department”). As relevant to this appeal, Snowden contends that defendant-appellee Ronald Korza, her bureau chief, violated her due process rights by making the decision to discharge her before she was granted a hearing on the charges culminating in her discharge 2 No. 22-1848 and before she was given the opportunity to respond to those charges. Because Korza was not the decisionmaker as to her discharge, and because Snowden has not presented evidence sufficient to support an inference that she was deprived of procedural due process. She had notice of the charges resulting in her dismissal and was given an opportunity to be heard (in writing) on those charges. Any concern raised by the fact that Korza had already made up his mind that she should be discharged prior to the July pre-disciplinary meeting and the submission of Snowden’s written rebuttal is resolved by the fact that he was not the individual authorized to make the discharge decision.

Affirmed

Decided 08/02/23

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