“due process did not require pre-termination proceedings before the [] RIF,” id. at 781, it nonetheless stressed the availability of post-termination relief, including “post-termination hearings if they believe either that their terminations were discriminatory or retaliatory, or that notice and separation procedures were not followed,” id. at 779. See also UDC Chairs Chapter, Am. Ass’n of Univ. Professors v. Bd. of Trs., 56 F.3d 1469 (D.C.Cir.1995) (finding university faculty who were denied summer deanship positions had no due process right to pre-termination procedures under the Mathews balancing test, but emphasizing their access to an extensive post-deprivation grievance procedure, including investigation by an impartial panel); Smith v. Sorensen, 748 F.2d 427, 436 (8th Cir.1984) (<HOLDING>). These decisions essentially stand for the
holding that due process does not require the state to provide an impartial decisionmaker at the pretermination hearing where posttermination remedies are available holding that a limited pretermination hearing was sufficient where it was followed by a more comprehensive posttermination hearing holding that due process requires a hearing appropriate to the nature of the case holding a judgment in the absence of notice violates due process rights holding that procedures that were available to the employees after the implementation of the rif guideline provided such protection of their rights that the absence of a pretermination hearing alone was not violative of due process