Circuits disclose two general types of contract rights that have been found to be property protected under the Fourteenth Amendment. As the Second Circuit noted in S & D Maintenance, 844 F.2d at 966, the first type arises where the contract confers a protected status, such as those “characterized by a quality of either extreme dependence in the case of welfare benefits, or permanence in the case of tenure, or sometimes both, as frequently occurs in the ease of social security benefits.” The second, albeit related type of property interest arises where the contract itself includes a provision that the state entity can terminate the contract only for cause. Id. at 967; see also Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 538-39, 105 S.Ct. 1487, 1491-92, 84 L.Ed.2d 494 (1985) (<HOLDING>); Arnett v. Kennedy, 416 U.S. 134, 166-67, 94
holding there were no grounds for challenging in a termination proceeding the alleged failure to comply with the ada in the provision of services because services are not required by the termination statute holding that although a reason was provided in the termination letter the without cause termination provision was applicable recognizing a property right created by a forcause termination provision recognizing right to cause of action as property right under navajo due process holding that a termination of benefits must go handinhand with a termination of the liability of an employer