Tenth Circuit: No Claim When Deputy Quit Rather than Accept Reassignment

In Lauck v. Campbell County, the Tenth Circuit upheld a district court's ruling that dismissed a case against a sheriff's department brought by a deputy after he was reassigned to the Civil Process Division. Although the deputy claimed that his reassignment constituted a demotion, because his pay and rank were the same before the transfer, the court held that the reassignment under the facts of this case did not constitute a breach of contract, a constructive discharge without due process, or a violation of First Amendment rights.