In Siegert v. Gilley (1991) 500 U.S. 226, the court modified this "stigma plus" approach. The lawsuit in that case flowed from a negative recommendation letter written by a former supervisor in the government agency in which Siegert was employed. Siegert argued that the combination of the allegedly malicious letter and his impaired ability to retain government employment satisfied the requirements of a constitutional liberty interest. He was not successful. Although the negative letter damaged his reputation and impaired future employment prospects, it was written several weeks after Siegert had resigned his position. (Id. at p. 233 111 S. Ct. 1789, 1793-1794.)