In Paul v. Davis, 424 U.S. 693 (1976) the United States Supreme Court found that the posting of a person's name and photograph on a poster captioned "Active Shoplifter" which resulted in inhibiting that person from entering stores for fear of being accused of shoplifting and the impairment of future employment opportunities, did not implicate due process concerns. The Court found an individual had no right to due process before police officers posted his picture with an identification as an "Active Shoplifter" in various retail establishments. That individual filed a 42 U.S.C. 1983 action, alleging his procedural due process rights were violated and claiming a protected interest in reputation and future employment opportunities. Paul, 424 U.S. at 701. Justice Rehnquist examined a long line of decisions in which the Court had protected an interest in reputation, and then wrote an interest in reputation is "neither 'liberty' nor 'property' guaranteed against state deprivation without due process of law." Id. at 712. The Court reasoned if the government's conduct is to be actionable, it must not only affect the individual's reputation but must be accompanied by some other injury. Paul, 424 U.S. at 708-10. The Court ruled "reputation alone, apart from some more tangible interests" is not deserving of protection. Id. at 701. This holding has come to be known as the "stigma-plus" requirement. The Court recognized that the posting in Wisconsin v. Constantineau deprived that person of the right, previously held under State law, to purchase liquor. It was the alteration of legal status coupled with the defamation which triggered the due process safeguards. ( Paul v. Davis, supra.) The Court concluded that due process protection applies whenever the State's action removes or significantly alters a protected status conferred and protected by State law. The alteration of such status triggers the procedural guarantees of due process. The interest in reputation without more is neither liberty nor property subject to due process protection. (Id. 424 US at 712.)