Source: cases/42usc1983/f4th-142-1053-eveland-v-city-of-st-louis.case
Case source: https://www.neochart.com/catalog/cases/f4th/volume_142/1053/index.html
Even assuming all of this is true, the firefighters had no property interests in their desired promotions that the due process clause protected.
casedsl 1.2 # author: Flash1 (gemini-3.8-flash-high) # triaged-by: Fable (2026-11-10) case /f4th/142/1053 name Eveland v. City of St. Louis cite 142 F.4th 1053 (2025) court United States Court of Appeals for the Eighth Circuit date 2025-07-08 url catalog/cases/f4th/volume_142/1053/index.html source ir/caselaw/f4th_142.jsonl sha1=4ffc95611392a66ddfcb6e6f6ad5fc6f55bd635f chars=4974 opinion maj : panel by Arnold @912..4939 controlling ? opinion: the IR text is a single paragraph (slip-opinion layout); the span starts at "ARNOLD, Circuit Judge." after the caption and ends at "Affirmed."; footnote 1 (the district judge's name) is embedded in the span. party city : City of St. Louis count promotion-dp : procedural due process claim for failure to promote to fire captain / battalion chief theory entitlement : regular practice of promoting the top scorer as the source of a legitimate claim of entitlement law 42usc1983 role applied posture civil; firefighters named to acting positions sued the city under § 1983 claiming that the failure to promote them deprived them of property without due process or just compensation; district court granted summary judgment for defendants; CA8 affirmed result claimant-lost element deprivation.due-process-property : not-satisfied [law] route public-employment pattern expected promotion from an exam shortlist where the fire chief had always picked the top scorer but kept discretion; promotions frozen by a superior party city count promotion-dp theory entitlement fact @2294..2375 [supports] | Under the present fire chief, this person has invariably been the highest scorer. fact @2376..2570 [supports] | And if this practice had continued, as the fire chief intended, each of the firefighters would have received a promotion because each would have been the highest scoring candidate for a vacancy. fact @2222..2293 [cuts-against] | From these candidates, the fire chief may select one person to promote. fact @3675..3773 [cuts-against absent] | What is missing is evidence that the city bound itself in some fashion to adhere to that practice. rule @3282..3387 [quoted] | “An employee’s unilateral expectations spawned by the regularized practices of his employer will not do.” held @2931..3075 | Even assuming all of this is true, the firefighters had no property interests in their desired promotions that the due process clause protected. gloss A regular practice of promoting the highest scorer, and the chief's intention to follow it, did not limit his discretion and so created only an expectation, not a property interest. The same reasoning disposed of the takings claim. ? basis: summary judgment for the city, but decided "even assuming all of this is true" on the firefighters' own account of the promotion process, so recorded as [law]; the court also notes missing evidence that the city bound itself to the practice, which would read as [no-evidence].