In Katzberg v. Regents of University of California (2002) 29 Cal.4th 300, a professor who had been removed as a department chairman during an investigation brought an action against university officials, seeking damages for an alleged violation of his liberty interest under the state Constitution's due process clause. (Katzberg, supra, 29 Cal.4th at p. 304.) The Supreme Court affirmed summary judgment in favor of the university. The Supreme Court held that an action for damages is not available for an alleged violation of a professor's liberty interest under the California Constitution. (Katzberg, at p. 303.) The Katzberg court recognized that an at-will public employee's liberty interests are deprived when his discharge is accompanied by charges that might seriously damage his professional standing or stigmatize him within the community. When such a deprivation of liberty occurs, the employee has a right to a "name-clearing hearing." (Katzberg, supra, 29 Cal.4th at p. 305.) The court held that a tort action for damages was not available since the professor had other meaningful remedies available, such as a petition for writ of mandate under Code of Civil Procedure section 1085. (Katzberg, at pp. 326-329.)