Gordon Bock v. Steven Gold

Summary

The court held that the amended complaint adequately pleaded a procedural due-process claim under 42 U.S.C. § 1983 against the named defendants in their individual capacities because, read as a whole, it gave fair notice that plaintiff challenged the process preceding revocation of his furlough. It affirmed dismissal of the § 1983 claims against defendants in their official capacities and of claims premised on the Vermont Constitution, while declining to address repleading because the complaint was sufficient. Justice Skoglund, joined by Justice Burgess, dissented from allowing the individual-capacity § 1983 claim to proceed, concluding that the allegations were conclusory and failed to provide fair notice.