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 The words 'liberty' and 'property,' as used in the Fourteenth Amendment, do not, in terms, single out reputation as a candidate for special protection over and above other interests that may be protected by state law. While courts have pointed out the frequently drastic effect of the 'stigma' which may result from defamation by the government in a variety of contexts, these line of cases does not establish the proposition that reputation alone, apart from some more tangible interests such as employment, is either 'liberty' or 'property' by itself sufficient to invoke the procedural protection of the Due Process Clause. The weight of decisions establishes no constitutional doctrine converting every defamation by a public official into a deprivation of liberty within the meaning of the Due Process Clause of the Fifth or Fourteenth Amendment. 


In United States v. Lovett, 328 U. S. 303 (1946), the Court held that an Act of Congress which specifically forbade payment of any salary or compensation to three named Government agency employees was an unconstitutional bill of attainder. The three employees had been proscribed because a House of Representatives subcommittee found them guilty of 'subversive activity,' and therefore unfit for ...

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