against the governmental defendants, this amended complaint added section 1983 claims against Ottum, Quinn, and Thompson. [¶ 14] Ottum, Thompson, and Quinn filed a summary judgment motion on February 1, 1999, asserting legislative and qualified immunity defenses. The Superior Court denied their motion. The court ruled, “[b]y 1996, it was well established ‘that a constructive discharge of a public employ ee without procedural due process constitutes an unconstitutional deprivation of property.’ Because their actions violated plaintiffs clearly established rights, defendants are not entitled to a qualified immunity as a matter of law.” II. STANDARD OF REVIEW [¶ 15] An order denying a motion for a summary judgment must be reviewed for errors of law. See Andrews v. Dep’t of Envtl. 1989) (<HOLDING>); Gates v. Sicaras, 706 F.Supp. 169, 172-73
holding that a suspension with pay does not violate any recognized property interest holding that a school principals suspension with pay did not implicate a constitutionally protected property interest holding that a twoday suspension with pay does not deprive plaintiff of measurable property interest holding that suspension with pay was not adverse employment action holding that a suspension with pay does not invade any recognized property interest