Martin Marietta Materials v. Kansas DOT

Martin Marietta Materials, Inc. appealed a district court’s dismissal of its due-process claims against the Kansas Department of Transportation (KDOT). After KDOT removed two Martin Marietta quarries from its preapproved lists of limestone aggregate suppliers, Martin Marietta unsuccessfully sought pre- and post-deprivation hearings from KDOT. Among its many claims in its federal lawsuit, Martin Marietta asserted a property-right claim under the Fourteenth Amendment, claiming a property interest in keeping its two quarries on “the approved list” of aggregate suppliers, and a liberty interest in its reputation as a supplier of quality materials under the Fourteenth Amendment. The district court disagreed, dismissing these claims on the pleadings. After review, the Tenth Circuit affirmed, holding that Martin Marietta had not plausibly alleged a protected property interest, and thus that KDOT did not violate Martin Marietta’s procedural-due-process rights by failing to provide pre- or post-deprivation hearings. Furthermore, the Court held that Martin Marietta had no cognizable liberty interest, because KDOT did not make defamatory statements about Martin Marietta and because Martin Marietta failed to allege sufficiently significant harm to its business. View "Martin Marietta Materials v. Kansas DOT" on Justia Law