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Pedenv.Stephens

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.24-10178
DecidedAugust 19, 2026
JudgesJill Pryor, J.; Branch, J.; Ed Carnes, J.
Tags
CivilCivil RightsDue ProcessDefamationStandingSection 1983Employment Law
Case Summary

After Gwinnett County sheriff’s deputy Chase Peden’s affair with Carole Stephens ended, she sent the Sheriff’s Office a letter signed “Michael” accusing him of having affairs while on duty, and her husband, County Administrator Glenn Stephens, later confirmed the affair to the chief deputy. The Sheriff’s Office moved to fire Peden for using his patrol vehicle to meet women for sex on duty without naming Stephens, a reporter obtained his personnel file, and Peden dropped his Merit Board appeal in exchange for being treated as having resigned. Peden and his wife then sued county officials in federal court. The Eleventh Circuit held that Peden’s procedural due process claims failed because he never used available Georgia remedies, including review before the full Merit Board, an appeal to superior court, and mandamus to obtain a name-clearing hearing. Under McKinney v. Pate, a public employee suffers no procedural due process violation unless the state refuses to provide a means to remedy the deprivation, and learning the true reason for his firing within a year did not foreclose those remedies. The court also held that his defamation claim rested on speculation about which official, if any, tipped the reporter. Finally, the court held that the Pedens lacked standing to challenge the district attorney’s decision not to prosecute Carole Stephens for stalking, because a private citizen has no judicially cognizable interest in another person’s prosecution, and it ordered that claim dismissed without prejudice.

Opinion

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