In Cleveland Board of Education v. Loudermill, 470 U.S. 532 (1985), the United States Supreme Court considered the extent of pretermination process to be accorded a public employee who can be discharged only for cause. Both consolidated cases in Loudermill involved a complete severance of the employment relationship and both involved allegations of the employee's fault (lying on an employment application) or deficiency (failure of an eye examination). Both the employees were discharged without even an informal opportunity to contest the facts on which their discharges were based. Both had plausible arguments to make that might have prevented their discharge. One, in fact, was reinstated after a post-termination hearing. The district court dismissed both cases for failure to state a claim for which relief could be granted. The Loudermill Court determined that where public employees have a property interest in continued employment, due process requires pretermination procedural safeguards. The pretermination hearing is "an initial check against mistaken decisions" and "need not definitively resolve the propriety of the discharge." 470 U.S. at 545-46. The Supreme Court of the United States recognized the difference between a posttermination hearing and a pretermination hearing. In Loudermill, terminated school-district employees sued the Cleveland Board of Education, alleging that their federal procedural-due-process rights had been violated because they were not provided an opportunity to respond to the charges against them. The Supreme Court held that tenured government employees almost always must be afforded at least a limited pretermination hearing before they can be constitutionally terminated. 470 U.S. at 542-43. The Supreme Court, however, held that the pretermination hearing need not be elaborate and need not be a full evidentiary hearing. Id. at 545. The Supreme Court reasoned that the purpose of a pretermination hearing is not to "definitively resolve the propriety of the discharge," but, rather, to "be an initial check against mistaken decisions--essentially, a determination of whether there are reasonable grounds to believe that the charges against the employee are true and support the proposed action." Id. at 545-46. The Supreme Court also noted that under state law the terminated government employee was later entitled to a full and adequate administrative posttermination hearing and judicial review. Id. at 545. Therefore, the Supreme Court concluded that under federal procedural-due-process law all that is required in a pretermination hearing is "oral or written notice of the charges against the employee, an explanation of the employer's evidence, and an opportunity for the employee to present his side of the story." Id. at 546. The Supreme Court then stated that "to require more than this prior to termination would intrude to an unwarranted extent on the government's interest in quickly removing an unsatisfactory employee." Id. The Supreme Court recognized that determining what procedural process is due requires a balancing of the parties' competing interests. 470 U.S. at 542-43. The Supreme Court stated that these interests are "the private interest in retaining employment, the governmental interest in the expeditious removal of unsatisfactory employees and the avoidance of administrative burdens, and the risk of an erroneous termination." 470 U.S. at 542-43. Because a full evidentiary hearing is not required at the pretermination level, id. at 545, it would be impractical to require a person unfamiliar with the subject matter of the allegations to conduct the pretermination hearing. We conclude that "the governmental interest in the expeditious removal of unsatisfactory employees and the avoidance of administrative burdens" of conducting a "mini-trial" to educate an impartial decision-maker outweighs the private interest in "retaining employment" and "the risk of an erroneous termination." Loudermill, 470 U.S. at 542-43.