In Board of Regents of State Colleges v. Roth (1972) 408 U.S. 564, an untenured professor of a state university was told he would not be rehired for the next academic year. (Id. at p. 566.) He was not given a reason for the decision or an opportunity to challenge it at a hearing. (Id. at p. 568.) The professor believed the decision was made to punish him for making statements critical of the university administration and therefore violated his right to freedom of speech. (Ibid.) He sued the Board of Regents of the university claiming that the failure to give him notice of a reason for nonretention and an opportunity for a hearing violated his right to procedural due process of law. (Id. at p. 569.) In rejecting the claim, the Supreme Court explained: "The State, in declining to rehire the respondent, did not make any charge against him that might seriously damage his standing and associations in his community. It did not base the nonrenewal of his contract on a charge, for example, that he had been guilty of dishonesty, or immorality. Had it done so, this would be a different case. For 'where a person's good name, reputation, honor, or integrity is at stake because of what the government is doing to him, notice and an opportunity to be heard are essential.' In such a case, due process would accord an opportunity to refute the charge before University officials." (Id. at p. 573.) The court noted that the "purpose of such notice and hearing is to provide the person an opportunity to clear his name. Once a person has cleared his name at a hearing, his employer, of course, may remain free to deny him future employment for other reasons." (Id. at p. 573, fn. 12.) The court concluded that such a hearing was not required in the case before it because "there is no suggestion whatever that the respondent's 'good name, reputation, honor, or integrity' is at stake." (Id. at p. 573.) The United States Supreme Court 'made clear that the property interests protected by procedural due process extend well beyond actual ownership of real estate, chattels, or money.' ( Id., at pp. 571-572.) Rather, 'the Fourteenth Amendment's procedural protection of property is a safeguard of the security of interests that a person has already acquired in specific benefits. These interests -- property interests -- may take many forms.' ( Id., at p. 576.) "Expanding upon its explanation, the Roth court noted: 'To have a property interest in a benefit, a person clearly must have more than an abstract need or desire for it. He must have more than a unilateral expectation of it. He must, instead, have a legitimate claim of entitlement to it. It is a purpose of the ancient institution of property to protect those claims upon which people rely in their daily lives, reliance that must not be arbitrarily undermined. It is a purpose of the constitutional right to a hearing to provide an opportunity for a person to vindicate those claims. "'Property interests, of course, are not created by the Constitution. Rather, they are created and their dimensions are defined by existing rules or understandings that stem from an independent source such as state law -- rules or understandings that secure certain benefits and that support claims of entitlement to those benefits.' ( Id., at p. 577.) The Supreme Court of the United States discussed what constitutes a constitutionally protected property interest: "To have a property interest in a benefit, a person clearly must have more than an abstract need or desire for it. He must have more than a unilateral expectation of it. He must, instead, have a legitimate claim of entitlement to it. It is a purpose of the ancient institution of property to protect those claims upon which people rely in their daily lives, reliance that must not be arbitrarily undermined. It is a purpose of the constitutional right to a hearing to provide an opportunity for a person to vindicate those claims. "Property interests, of course, are not created by the Constitution. Rather, they are created and their dimensions are defined by existing rules or understandings that stem from an independent source such as state law -- rules or understandings that secure certain benefits and that support claims of entitlement to those benefits." 408 U.S. at 577. The United States Supreme Court set forth conditions that trigger due process protections: "a person clearly must have more than an abstract need or desire for it. He must have more than a unilateral expectation of it. He must instead, have a legitimate claim of entitlement to it ... Property interests, of course, are not created by the Constitution. Rather, they are created and their dimensions are defined by existing rules or understandings that stem from an independent source such as state law--rules or understandings that secure certain benefits and that support claims of entitlement to those benefits." (id. at 577). The Supreme Court observed that property interests protected by procedural due process extend beyond actual ownership of real estate, chattels or money, the decision did not establish that such rights are unlimited. ( Id., at p. 572.) The court observed that in order to have a valid property interest which may be entitled to due process consideration, a person must have more than an expectation or need of a particular benefit -- he must have a legitimate claim of entitlement to it. Such interests are created, not by the Constitution but by "rules or understandings" that stem from some independent source, such as state law. It is these "rules or understandings" which support certain specific claims of entitlement to benefits. ( Id., at p. 577.) In Roth, a nontenured assistant professor contested his dismissal from a teaching appointment in the Wisconsin University system upon expiration of his one-year contract. The contract did not provide for renewal, and as a nontenured employee, Roth had no rights to renewal under Wisconsin law. Consequently, the court held that he had no cognizable property interest under the 14th Amendment. (408 U.S. at p. 578 33 L.Ed.2d at p. 561.) The Supreme Court reasoned that termination of an untenured professor did not deny due process because: "The State, in declining to rehire the respondent, did not make any charge against him that might seriously damage his standing and associations in his community. It did not base the nonrenewal of his contract on a charge, for example, that he had been guilty of dishonesty, or immorality. Had it done so, this would be a different case. For 'where a person's good name, reputation, honor, or integrity is at stake because of what the government is doing to him, notice and an opportunity to be heard are essential.' In such a case, due process would accord an opportunity to refute the charge before University officials. In the present case, however, there is no suggestion whatever that the respondent's 'good name, reputation, honor, or integrity' is at stake. "Similarly, there is no suggestion that the State, in declining to re-employ the respondent, imposed on him a stigma or other disability that foreclosed his freedom to take advantage of other employment opportunities. The State, for example, did not invoke any regulations to bar the respondent from all other public employment in state universities. Had it done so, this, again, would be a different case. For 'to be deprived not only of present government employment but of future opportunity for it certainly is no small injury . . . .' " (Ibid.)