Full opinion text
DECISION AND ORDER RANDA, District Judge. This matter comes before the Court on defendants’ joint motion for summary judgment. For the following reasons, the motion is granted as to plaintiffs federal claims, which are dismissed. In light of the dismissal of the federal claims — which provided the basis for the Court’s subject matter jurisdiction — the Court declines to exercise its supplemental jurisdiction over the remaining state law claims, which are remanded to state court. I The following facts are undisputed. In or around August, 1995, the Merton Community School District (“MCSD” or “School District” or “School Board”) hired Susan Ulichny (“Ulichny”) to serve as a District Principal. (Defendants’ Proposed Findings of Fact (“DFOF”) at ¶ 1; Plaintiffs Response to DFOF (“PR”) at ¶ 1.) Ulichny’s initial contract was for roughly one year, spanning from August 14, 1995 to July 9, 1996. (Ulichny Aff., Ex. 2. at 1.) Renewal and/or non-renewal of the contract was governed by Wis. Stat. § 118.24, which generally provides that a principal’s contract is automatically renewed for a subsequent term unless the school board provides a notice of non-renewal to the principal at least four months prior to the contract’s expiration. (Id. at 3.) See also, Wis. Stat. § 118.24(6). Absent non-renewal, the contract could only be terminated by mutual consent of the parties or by the School Board upon a showing of “just cause” after providing Ulichny with notice and an opportunity to be heard. (Id.) Under the “RESPONSIBILITIES” section of the contract, Ulichny agreed, inter alia, ... to perform at a professional level of competence the services, duties and obligations required by the laws of the State of Wisconsin and the rules, regulations and policies of the Board which are now existing or which may be hereinafter enacted by the Board. [and] ... to devote full time to the duties and responsibilities normally expected of the Principal’s position during the term of this contract, and shall not engage in any pursuit which interferes with the proper discharge of such duties and responsibilities. (Id. at 1.) The School Board, in turn, agreed “to furnish [Ulichny] with a written copy of all ... rules, regulations and policies now in effect or becoming effective during the term of this contract,” and to further “provide [Ulichny] with a written job description of the services, duties and obligations” of the Principal position. (Id.) At the time Ulichny was originally hired, Bruce Connolly (“Connolly”) was the District Administrator for the MCSD. (Plaintiffs Proposed Findings of Fact (“PFOF”) at ¶4.) It appears Ulichny was initially assigned to serve as the K-8 Principal of the Merton School, an entity housing some 730 students. (DFOF at ¶ 4; PR at ¶ 4; Connolly Aff., Ex. B at 1.) Connolly subsequently evaluated Ulichny’s performance during her first year. (DFOF at ¶ 4; PR at ¶ 4.) As part of that process, Connolly reviewed feedback forms that had been filled out by staff and teachers at Merton School. (Connolly Aff., Ex. C; DFOF at ¶ 5; PR at ¶ 5.) The feedback forms both praised and criticized Ulichny, identifying many areas of strength and also many areas of weakness. (Connolly Aff., Ex. C; PFOF at ¶¶ 6-7; DFOF at ¶¶ 7-8; PR at ¶¶ 7-8.) Similarly, Connolly’s formal, written evaluation of Ulichny’s first-year performance — issued September 23, 1996 at or near the beginning of Ulichny’s second school year — was a mixed bag of identified strengths, weaknesses, and areas for improvement. (Connolly Aff., Ex. B.) Ultimately, Connolly concluded that he “would not characterize Mrs. Ulichny’s first year as a completely successful one” and that “some of the negatives outweighed the positives.” (Id. at 10.) Accordingly, Ul-ichny was provided with various recommendations and expectations for her second school year, and Connolly expressed his expectation that Ulichny would draft a written plan for improvement. (DFOF at ¶ 12; PR at ¶ 12; Connolly Aff., Ex. B at 10.) Shortly thereafter, Connolly resigned his position as District Administrator, effective October 1, 1996. (PFOF at ¶ 4.) Approximately four weeks later, Connolly was replaced (temporarily) by Michael Bu-disch (“Budisch”), who served as Interim District Administrator. (Id.) Budisch subsequently evaluated Ulich-ny’s performance during her second school year and reviewed additional feedback forms from teachers and staff. (DFOF at ¶ 16; PR at ¶ 16; Budisch Aff. at ¶ 4, Ex. D.) As was the case with Ulichny’s first year evaluation, the feedback forms were a mixed bag of praise and criticism, and a review indicates that the staff and teachers were quite divided on the merits of Ulich-ny’s performance — some thought very highly of her, others had equally strong concerns. (Budisch Aff., Ex. D.) Because of the uneven nature of the staff evaluations, the School Board served Ulichny with preliminary notice of non-renewal on January 31, 1997, pursuant to Wis. Stat. § 118.24(7). (Budisch Aff., Ex. E.) As indicated earlier — see, footnote 1, supra— this document served notice on Ulichny that the School Board was considering the non-renewal of her contract and that she was entitled to a hearing before the Board prior to a final decision. As was her right, Ulichny requested a private hearing before the Board with her lawyer and members of the Intermediate Advisory Council present. (DFOF at ¶ 21; PR at ¶ 21; Budisch Aff., Ex. F.) Her request was granted and a private hearing was scheduled for February 26, 1997. (DFOF at ¶¶ 22-24; PR at ¶¶ 22-24.) Ulichny and various staff members who supported her spoke at length at the hearing about the criticisms that had been leveled against her through the staff and teacher feedback forms. (Budisch Aff., Ex. H at 2-76.) Much of the discussion focused on criticisms alleging a negative “school climate,” “strained relationships” and/or poor communication between Ulichny and some members of the staff. (Id.) On March 7, 1997, The School Board notified Ulichny that it was not renewing her contract. (DFOF at ¶ 32; PR at ¶ 32.) However, the School Board offered her a one-year contract for the 1997-98 school year as the Merton Intermediate School Principal. (DFOF at ¶ 33; PR at ¶ 33.) Ulichny accepted the offer. (DFOF at ¶ 34; PR at ¶ 34.) Ulichny signed her new one-year contract on April 8, 1997, the relevant terms of which were identical to those in her prior contract. Subsequently, the School Board issued a formal, written evaluation of Ulichny’s performance during the 1996-97 school year. (Budisch Aff., Ex. L.) Consistent with the criticisms leveled against Ulichny by some of the staff and teachers, the School Board concluded that “Ms. Ulichny’s leadership skills need a great deal of improvement” and “that a large group [of faculty and staff] lacks confidence in her abilities as a principal.” (Id.) The School Board cited “school improvement, school climate, leadership, and interpersonal relationships” as the areas where there was “a significant need for improvement on Ms. Ulichny’s behalf.” (Id.) The Board suggested that Ulichny “register for classes and workshops” to help her improve in those areas and stated its “expectation ... that there will be measurable and significant improvement” in Ulichny’s performance. (Id.) The Board also directed that Ulichny agree to a formal “plan of assistance” that included “a process of continuous evaluation and feedback on the areas previously noted” and “goals and steps to accomplish these goals.” (Id.) On July 1, 1997, Mark Flynn (“Flynn”) was hired as District Administrator. (DFOF at ¶ 41; PR at ¶41.) In accordance with the Board’s direction, Flynn prepared a formal assistance plan for Ul-ichny, dated August 7, 1997, which identified four areas for improvement — school climate, leadership skills, interpersonal skills and communication skills — and listed various goals and concrete actions for Ul-ichny to perform along with corresponding timetables for reaching or completing the same. (DFOF at ¶ 43; PR at ¶ 43; Flynn Aff., Ex. N.) The plan provided for weekly meetings between Flynn and Ulichny to monitor her progress in team building skills and healthy communication (DFOF at ¶ 45; PR at ¶45.) In addition, Flynn was to prepare quarterly written progress reports regarding Ulichny’s development on each of November 1, January 1, March 1 and June 15. (PFOF at ¶ 11; Defendant’s Response to PFOF (“DR”) at ¶ 11; Flynn Aff., Ex. N.) Flynn also gave Ulich-ny — at her request — a memo outlining the deadlines applicable to the renewal and/or non-renewal of her contract, which was set to expire on June 26, 1998. (DFOF at ¶ 47; PR at ¶ 47.) On October 14, 1997, five or six 7th and 8th grade students were involved in a playground incident whereby they surprised another boy, forced him to the ground, and gave him what is commonly referred to as a “wedgie,” ie., they grabbed the top of his underwear from his backside and pulled up forcibly. (DFOF at ¶ 48; PR at ¶ 48; PFOF at ¶¶ 13-14.) Distraught, the boy ran to Principal Ulichny’s office in tears, related what happened and asked if he could call his mother because he needed a new pair of underwear. (PFOF at ¶ 13.) Ulichny called District Administrator Flynn, related the situation and suggested that they call the sheriffs department. (PFOF at ¶ 15.) Flynn agreed. (Id.) Ul-ichny then called the school’s D.A.R.E. officer, Deputy Haizel (“Haizel”), because he had a long relationship with the students at Merton Intermediate School. (Id.) After speaking with Ulichny, the students involved, and some of the students’ parents, Deputy Haizel issued each of the students (other than the victim, of course) a citation for disorderly conduct. (PFOF at ¶¶ 17-19.) Ulichny then notified the relevant parents of the incident, the involvement of law enforcement and the issuance of disorderly conduct citations, and her corresponding decision to discipline the students with suspensions. (DFOF at ¶ 50.) Some of the parents expressed their belief to Deputy Haizel and/or Ulich-ny that the incident was being blown out of proportion and threatened'to complain to the School Board. (PFOF at ¶¶ 17-18.) The “wedgie” incident garnered a great deal of media attention, both locally and nationally. (PFOF at ¶ 20.) Local newspaper stories reported details of the incident, including the criticisms of some of the parents regarding the manner and harshness of the disciplinary measures taken. (Ulichny Aff., Ex. 10.) The School District also began to receive responses from the community regarding the incident, some of which supported Ulichny’s actions and some of which criticized the same. (PFOF at ¶ 22; DR at ¶ 22.) A petition began circulating in the community requesting an investigation into the handling of the incident. (Id.) Nevertheless, from the day the incident happened and throughout November of 1997, Flynn publicly supported Ulichny’s actions, and some of his statements of support were quoted in local newspaper stories stemming from the incident. (PFOF at ¶ 23.) On November 6, 1997, while the public fallout from the “wedgie” incident was still developing, Flynn gave Ulichny her first' quarterly progress report in accordance with her assistance plan, discussed supra. (DFOF at ¶ 55; PR at ¶ 55.) It was quite positive. (Flynn Aff., Ex. S.) Flynn summarized his report by stating that “Susan has demonstrated good performance in her role as Principal” and by noting “her willingness, with results, to actively participate in the improvement process thrust upon her by the Board and the Superintendent.” (Id.) The positive report was consistent with the results of a staff survey conducted by an outside consultant during the month of, November, 1997 at the School District’s request. (Ulichny Aff., Ex. 3.) The survey report noted an improvement in school climate in terms of communication, trust and reduced gossip. (Id.) The report cited “improvement in the relationship between Ms. Ulichny and the professional teaching staff’ and noted that, while “some distrust remain[ed],” it was “on a subdued level since the 1996-97 school year.” (Id.) On December 12, 1997, Flynn gave Ul-ichny her second quarterly progress report. (DFOF at ¶ 57; PR at ¶ 57.) It was also quite positive. (Flynn Aff., Ex. S.) Flynn summarized his report by stating that “Susan continues to improve as a principal.... Her improvement orientation, her introspection, are exemplary.” (Id.) Three days after this report, Flynn submitted a confidential report to the School Board regarding Ulichny’s contract status and the progress of her assistance plan. (Ulichny Aff., Ex. 35.) The report was designed to assist the Board in making its decision regarding the possible renewal of Ulichny’s contract, a decision which had to be made no later than January, 1998.(Id.) The report listed specific areas of strength, areas of improvement, and areas for future growth. (Id.) Overall, the report was very positive and painted a picture of a principal and a school that had substantially improved. (Id.) Flynn concluded by recommending that the School Board issue Ulichny a 2-year contract: Mrs. Ulichny has earned a 2 year contract. My impression was that I started with a first year principal. Improvement has been substantial and her improvement orientation will continue to help her improve. Her performance has been good this year, she has the potential to improve and has served the district well. .... Many times there currently exists with the employees and the community a propensity to make Susan the issue, instead of children being the issue. The support of a 2 year contract reduces that propensity. (Id.) On December 15th, the Board voted' — in closed session — to issue a two year contract to Ulichny, which would cover the 1998-99 and 1999-2000 school years. (PFOF at ¶ 30.) That same day, an article ran in a local newspaper stating that the School Board intended to conduct a review at its December 15th meeting of the manner in which the “wedgie” incident was handled, although Flynn was again noted as having said the matter was handled appropriately. (Ulichny Aff., Ex. 18.) The story indicated that a School Board member had urged the reporter who wrote the story to hold off printing the same until after the December 15th Board meeting took place, stating that the furor over the incident had died down and she was concerned that another story “would make it flare up again.” (Id.) Interestingly, the subject of Ulichny’s possible contract renewal was never discussed in the news story, suggesting that the same had been kept confidential. (Id.) A second story ran on January 19, 1998, disclosing that the School Board planned to meet in closed session on January 20th to question the administrators, students, parents and sheriffs personnel involved in the “wedgie” incident. (Ulichny Aff. Ex. 19; PFOF at ¶¶ 32-33.) During that meeting, some of the parents criticized Ulichny’s actions and some of the parents supported them, but Flynn again spoke in strong support of Ulichny’s actions, stating that “Susan ... had my 100 percent support [... ] [a]nd has it to this day.” (PFOF at ¶¶ 33-38.) Soon thereafter, some of the parents within the School District learned of Ulich-ny’s contract renewal. In late January or early February, 1998, Jeffrey Musche (“Musche”), a parent of a child in the School District, complained that the Board violated Wisconsin’s Open Meetings Law, Wis. Stat. § 19.81 et. seq., by not informing the public or voting in open session regarding Ulichny’s contract renewal. (DFOF at ¶ 63; PR at ¶ 63; Ulichny Aff., Ex. 20.) The complaint was apparently referred to Waukesha County District Attorney Paul Bucher, who was quoted in a February 4, 1998 newspaper article as saying that he was investigating the matter because the closed session and vote “appear[ed] to be a violation of the open meetings law.” (PFOF at ¶ 40.) After Flynn discussed the matter with Bucher, the Board met on February 16, 1998 and apparently voted to rescind the prior vote on Ulichny’s contract. (DFOF at ¶ 65; PR at ¶ 65.) The Board initially planned to conduct another vote on the contract that night in open session, but the vote was delayed until February 19,1998, ostensibly to allow the Board to consult with legal counsel. (Ulichny Aff., Ex. 26.) According to newspaper reports, however, the vote was delayed because a large group of parents attended the meeting and voiced their, strong objections against renewing Ulichny’s contract. (PFOF at ¶ 42; Ulich-ny Aff. Exs. 22, 23 & 25.) Some parents also criticized Flynn’s evaluation of Ulich-ny, as well as various other alleged problems within the School District, including low teacher morale, teacher turnover, student achievement, an unsettled teachers’ contract, delayed textbooks, and students’ academic placement upon entering the local high school. (PFOF at ¶ 44; Ulichny Aff., Ex. 25.) Newspaper reports following the meeting paraphrased and/or quoted Flynn as taking the following positions with respect to Ulichny and/or the other issues raised: Superintendent Mark Flynn had' completed Ulichny’s evaluation. He has steadfastly upheld her decision to call law enforcement to the school. sH ^ »!* •!* [Flynn] went on to say that he shared some of the concerns raised by the residents, including: teacher morale, lack of trust, the public’s regard for the administration, an unsettled teachers’ contract, teachers’ regard for the board and teacher turnover. [Flynn] said there is a misperception as to why some teachers have left the district. The reasons are stated in correspondence the district has received from the teachers. He did not elaborate on the reasons. Flynn also addressed concerns that had been raised about textbooks, students’ placement at Arrowhead High School and curriculum.... [Flynn] added he is looking at providing time for teachers to talk to each other about educational strategies.... (Ulichny Aff., Ex. 25.) Asked about parents’ complaints, Superintendent Mark Flynn said: “I’m not going to substantiate, or deny them. It was these parents’ opportunity to state their perceptions and that’s what they did.” Parents of the youths said administrators overreacted by calling police. But Flynn said the district acted appropriately. (Ulichny Aff., Ex. 23.) These articles also quoted School Board President Isabel Brown as stating that, although a number of parents at the meeting demanded Ulich-ny’s removal, “[pjrobably we have more people who want her to stay than want her out.” • (Id.) The Board met again on February 19, 1998 and discussed the question of renewing Ulichny’s contract in open session. (DFOF at ¶ 76; PR at ¶ 76.) Because the deadline for providing Ulichny preliminary notice of non-renewal under Wis. Stat. § 118.24 had passed, the Board had little choice but to renew Ulichny’s contract. (DFOF at ¶ 77; PR at ¶ 77; PFOF at ¶ 56.) Consequently, a majority of the Board voted “to continue Susan Ulichny’s employment with the Merton Community School District with a revised job title and description beginning with the 1998-99 school year.” (PFOF at ¶ 58.) The next day, February 20, 1998, Flynn sent a memo to all district employees stating, in pertinent part: The school board was advised by legal counsel of the fact that statutory time-lines provided for the renewal of the employment contract for Ms. Ulichny whether the board acted or not. Given that advice, the board acted to continue Ms. Ulichny’s employment contract with the Merton Community School District for the next 2 years with a revised job title and description, beginning with the 98-99 school year. The board, after lengthy discussion, took this action in response to: contractual obligations, statutory requirements, staff input, board input, parent input, and taxpayer interest. The board, in the coming months, will approve revised job duties for administrative staff that are responsive to the input received from staff and parents. (Ulichny Aff., Ex. 36.) The same basic information was sent to all the parents of students in Merton. (Id., Ex. 37.) In addition to the District’s own publicized statements, the Milwaukee Journal Sentinel publicized the Board’s actions, reporting that the Board “could strip [Ulich-ny] of her duties as principal at the end of the school year” and quoting Board President Brown as stating that Ulichny’s revised job duties “could lead to her not being principal,” although Brown pointed out that nothing firm had been decided yet. (Ulichny Aff., Ex. 38.) Other sections of the article quoted Brown and Flynn as follows: [Ulichny’s] new duties likely will include some of the areas [she] now handles, such as curriculum and technology, Brown said. “She will be the principal for the balance of this year,” Brown said. “We’re hoping that the rest of the year goes well ... We will be working with Susan and the staff to see where her abilities fit in best.” * * * ❖ ❖ * Superintendent Mark Flynn said Friday that he understands parents remain upset about the contract extension. But he said the board’s decision took into account both negative and positive comments the district received about Ulich-ny, the district’s contractual obligations, a responsibility to taxpayers, and Ulich-ny’s 2]é years of employment in Merton Schools. ‘When the job responsibilities are finalized, I think people will be able to readily see the board is responding in the best interests of the children of Merton schools,” Flynn said. “This is the start of a process of change.” (Id.) Another article, appearing in the Lake Country Reporter, reported that Ul-ichny would be allowed to stay on at Merton Intermediate school for at least two more years, “but she may no longer be principal of the school.” (Ulichny Aff., Ex. 39.) The article quoted and/or paraphrased Flynn as follows: “There will be some shifting of job responsibilities,” said superintendent Mark Flynn. “She could feasibly not be the principal of Merton Intermediate School.” sjí Hí ‡ ❖ “I’m confident we can put together a plan that will work for the children and be responsive to their needs,” said Flynn, adding that the Board was trying to accommodate the needs of everybody involved. “The board feels that the plan is responsive to the concerns of the board, staff and parents,” he said. “The division of duties is something that will reflect the concerns that the community and staff indicated they wanted.” Flynn said neither he nor the board had decided on any specific changes to Ulich-ny’s job description. Throughout the controversy, Flynn and the school board have stood behind their principal, but at a raucous meeting last week a number of parents spoke out criticizing [Ulichny’s] conduct and asking for her dismissal. * :¡: * i'fi * [Flynn] did not describe the board as having been “forced” to keep Ulichny on, but did say that “the time had passed” when the board could have asked her to leave. (Id.) During this time frame, on or around February 17, 1998, Vicky J. Wedig (“Wed-ig”) of the Waukesha Freeman submitted an “open records” request under Wisconsin’s Public Records Law, Wis. Stat. § 19.31, et. seq., seeking “copies of letters parents have written to the Merton School Board and administrators regarding Merton Intermediate School Principal Susan Kirchen-Ulichny.” (DFOF at ¶ 74; PR at ¶ 74; Flynn Aff., Ex. Z.) Roughly one week later, on February 25, 1998, Michael B. Johnson (“Johnson”) of the Milwaukee Journal Sentinel submitted another “open records” request, seeking “copies of all documents ... related to the employment and contract of ... Susan Ulichny,” including, but not limited to, the following: (1) Any letters written by parents and others in support of Ulichny; (2) any letters written by parents and others against Ulichny; (3) copies of letters and petitions related to the October attack on the playground; (4) copies of any responses from either the School Board or district administrators in response to these letters, petitions or other documents; (5) a copy of Ulichny’s contract and her job description as well as goals spelled out by the School Board and district administrator for her to meet; and (6) copies of any letters of commendation or reprimand that have been placed in Ulichny’s file. (Flynn Aff., Ex. DD.) The School District informed Ulichny and/or her counsel of the open records requests. (PFOF at ¶ 63.) Ulichny, through her counsel, asked the District not to release the letters from the parents, stating that Flynn himself acknowledged that the letters contained falsehoods and thus it was clear that releasing the information would harm Ulichny’s reputation. (Westerhof Aff., Ex. 75.) On March 10, 1998, the District informed Ulichny that it had decided to make the requested documents available to the inquiring press, subject to conditions including redaction of student names and information, and the opportunity for the authors and Ulichny to inspect the documents pursuant to Woznicki v. Erickson, 202 Wis.2d 178, 549 N.W.2d 699 (Wis.1996), and to seek circuit court review of the District’s decision. (DFOF at ¶ 85; PR at ¶ 85.) The District gave Ulichny until 2:00 p.m. on March 18, 1998 to seek circuit court review of its decision, at which time — if no such action was filed— the District intended to turn the records over to the Milwaukee Journal Sentinel and the Waukesha Freeman. (DFOF at ¶ 86; PR at ¶ 86.) The next day, March 11, 1998, the District sent copies of the documents it intended to produce to Ulich-ny’s counsel. (DFOF at ¶ 87; PR at ¶ 87.) Ulichny and her counsel responded by stating that, to the extent that the District believed that certain documents were inaccurate, it had an affirmative obligation to inform the newspapers of those inaccuracies at the time of disclosure. (Westerhof Aff., Ex. 77.) In addition, Ulichny stated there were other documents responsive to the requests which were not among those listed to be produced and which she would produce herself if the District did not do so. (Id.) The District refused to produce these additional documents, taking the position that such documents did not fall within the scope of the requests. (Wester-hoff Aff., Ex. 78.) In addition, the District refused to comment one way or another on the veracity of any of the documents produced, taking the position that the open records law does not impose such an obligation and, in any event, the District had no official belief or opinion in this regard to communicate. (Id.) In the end, Ulich-ny did not seek judicial review of the District’s decision to release the documents. (DFOF at ¶ 92; PR at ¶ 92.) Meanwhile, local newspapers continued to report on the situation. On March 17, 1998, the Waukesha Freeman paraphrased Flynn as stating that the Board “may revise Ulichny’s job title and will reassign some of her traditional principal duties to other administrators,.... ” (Ulichny Aff., Ex. 44.) In the same article, Timothy O’Neill — -at the time a non-incumbent candidate for the Merton School Board — was quoted as stating his opinion that “[Ulich-ny’s] role should be one that does not interact with the kids” and his understanding that parents had accused Ulichny of “ ‘bull[ying]’ kids” and “lie[ing].” (Id.) The article also paraphrased Flynn as saying that “it would be presumptuous to say whether Ulichny’s revised role will exclude interaction with children.” (Id.) A March 19, 1998 article by the Milwaukee Journal Sentinel noted that Ulichny “would have a new job title and job duties that could lead to her not being principal this fall.” (Ul-ichny Aff., Ex. 45.) The article also paraphrased Board President Brown as stating that “Ulichny ... has been put in a tough position because people told her there needed to be more discipline.” (Id.) And a March 23, 1998 article in the Waukesha Freeman again noted that the Board “plans to reassign some of [Ulichny’s] duties’ and reiterated O’Neill’s opinion that Ulichny should be given duties that do not involve interaction with kids.” (Ulichny Aff., Ex. 46.) On March 25, 1998, Ulichny accepted her 1998-2000 contract, the relevant terms of which were identical to her prior contracts. (Flynn Aff., Ex. KK.) In or around that same time frame, Flynn asked Ulich-ny to assist him in drafting her revised job duties. (PFOF at ¶ 75; DR at ¶ 75.) Ul-ichny essentially refused, stating that she could perform all of her current job duties. (Id.) Flynn then drafted the proposed changes himself, and he provided a copy of his “proposed job description and title changes” to Ulichny three days before they were to be presented to the School Board at a scheduled April 20, 1998 Board meeting. (PFOF at ¶¶ 78, 80; DR at ¶¶ 76-81.) By a letter of that same date, Ulichny — through her counsel — objected to the proposed changes as violating her contract, the Wisconsin statutes, and her due process rights. (Westerhof Aff., Ex. 81.) Ulichny also stated that any public release of the proposed changes would violate her alleged due process/liberty interest in her reputation, and therefore she urged the District to consider Flynn’s proposal in closed session and not release any documents related thereto to the public. (Id.) The District did not respond to Ulich-ny’s letter. (PFOF at ¶ 89; DR at ¶¶ 84-92.) The April 20, 1998 Board meeting was conducted in open session — with two reporters and several community members present — and the proposed changes were described by Flynn and “briefly discussed” by the Board. (Ulichny Aff., Ex. 54.) Under the proposed changes, Flynn was to become the Intermediate School Principal in addition to being the District Administrator. (PFOF at ¶ 92; DR at ¶¶ 84-92; Ulichny Aff., Exs. 52, 56.) Mike Budisch, who was previously the K-3 Primary School Principal, would serve as the K-5 Principal. (Id.) Ulichny would “assist” Flynn in the administration of the Intermediate School, while retaining her salary and the title of School Principal. (Id.) She would lose specific authority to perform many of the duties which she had performed previously- — -including (but not necessarily limited to), the following: (1) teacher and support staff supervision and evaluation, (2) student discipline, (3) bus referrals, (4) PTA duties, and (5) advisory committee duties. (Id.) Most of these duties were to be transferred to Flynn, while others were transferred to Budisch. (Id.) The proposed changes, however, were not formally adopted by the Board. (DFOF at ¶ 102; PR at ¶ 102.) Instead, the changes were set aside for a “second reading” and a vote at a future Board meeting. (DFOF at ¶ 101; PR at ¶ 101.) Nevertheless, after the April 20th Board meeting, articles in local newspapers reported the proposed changes and generally stated that Ulichny was being stripped of her supervisory duties over teachers and students. (Ulichny Aff., Exs. 55-57.) The Board scheduled a meeting for May 18, 1998 to vote on the proposed job changes. (PFOF at ¶ 97; DR at ¶ 97.) Before this meeting, on May 15, 1998, Ul-ichny served a Notice of Claim and Claim on the Clerk of the Merton School Board, which generally described the circumstances of her claim and provided an itemized statement of the relief sought. (Id.) In response, the Board removed the scheduled vote on the proposed job changes from its formal Agenda for the May 18th meeting. (PFOF at ¶ 99.) Instead, the Board went into closed session “to confer with legal counsel and receive advice concerning strategy to be adopted with respect to litigation which is likely to occur.” (PFOF at ¶ 100.) The District subsequently released a copy of the Notice of Claim and Claim to the Milwaukee Journal Sentinel, Waukesha Freeman and Lake Country Reporter without providing Ulichny with notice or an opportunity to object. (PFOF at ¶ 98.) Stories regarding the Notice of Claim and Claim ran in all three papers, and also in the Wisconsin State Journal. Beginning in or around this time, Flynn began sending memos to Ulichny criticizing what Flynn viewed as various lapses in her duties or performance. (PFOF at ¶¶ 108-109.) Ulichny received such memos on May 12, May 15, May 22, June 1, June 7, August 3 and August 11, 1998.(Id.) Ulichny cannot recall ever receiving such critical memos from Flynn in the past. (Id.) Moreover, Flynn did not conduct the March 1 and June 15 quarterly progress reports called for by the assistance plan put in place when Ulichny was re-hired for the 1997-98 school year. (PFOF at ¶ 110.) Flynn did prepare a year-end evaluation of Ulichny’s performance, however, dated July 7, 1998. (Id.; Flynn Aff., Ex. PP.) He did not share or discuss this evaluation with Ulichny at the time. (PFOF at ¶ 110.) The evaluation cited regression in many “critical areas” since the improvements that were noted in Ulichny’s first two quarterly progress reports, and concluded that such regression, “if not reversed,. will result in a short-term, unsuccessful employment relationship with the Merton Community Schools.” (Flynn Aff., Ex. PP.) In a memo to Ulichny dated August 3, 1998, Flynn set forth certain “[c]oncrete changes” which were to take effect for the upcoming 1998-99 school year. (Flynn Aff., Ex. QQ.) Under the category of “Visibility/Supervision,” the memo set forth a schedule which required Ulichny to be on the playground for a half hour before school, in the lunch room and on the playground for all three lunch periods of the Intermediate School, in the halls when the 7th and 8th graders changed classes, and in the halls and outside school during school dismissal and bus departure. (Id.) Under “Employee Supervision,” the memo stated that all teachers would be supervised and evaluated directly by Flynn, and that Ulichny would “assist with scheduling issues” and would be “assigned specific teacher evaluations .... [to] participate in.” (Id.) Under “Student Discipline,” the memo stated that Ulichny would handle student discipline in grades 4-6, while Flynn would handle discipline in grades 7-8 “and all suspension/law enforcement situations.” (Id.) Under “School/Community Newsletter,” the memo stated that Ulichny and Flynn would work together to “set a schedule and contents” for the school newsletter. (Id.) Under “NCA and Curriculum Evaluation,” the memo stated that Ulichny would “provide the administrative leadership in these 2 areas.” (Id.) Under “Intermediate Advisory Council,” the memo stated that Flynn would work directly with the advisory council, and that Ulichny “may participate if [Flynn] deem[ed] it appropriate, but not in the beginning.” (Id.) Under “Support,” the memo stated that Ulichny was “.expected to support and carry out in spirit and letter, the positions, policies, and directions of the school board and superintendent ... [a]greement with the decision is not relevant.” (Id.) On August 5, 1998, Flynn and Ulichny— along with their respective counsel — met to discuss her changed job responsibilities. (DFOF at ¶ 108; PR at ¶ 108.) Flynn produced notes of the meeting. (Flynn Aff., Ex. RR.) According to those notes, Flynn and/or District counsel raised issues concerning Ulichny’s job performance, including her failure to progress in inspiring trust, lack of attendance at special events, lack of judgment, and noncompliance with directives. (Id.; DFOF at ¶ 109; PR at ¶ 109.) Some of the more important changes listed in the August 3rd memo were also discussed. For example, in the area of “Student Discipline,” Flynn stated that he would assume a “mentoring role on a temporary basis in grades 7-8” and that Ulichny would handle grades 4-6 “except special education and suspensions.” (Flynn Aff., Ex. RR.) Flynn described his “mentoring role” as “[himself] handling some cases, others handled as a team, others with consultation, and some delegated to [Ulichny],” all at Flynn’s discretion. (Id.) In the area of “Employee Supervision,” Flynn stated that he would again assume a “mentoring role” with regard to “the supervision of all employees at the Intermediate School, for day-to-day purposes as well as evaluation purposes.” (Id.) Flynn’s “mentoring role” was again described as “[Flynn] exclusively handling some matters/cases, others handled as a team, others with consultation and some delegated to [Ulichny],” all at Flynn’s discretion. (Id.) Flynn explained that these changes “were being taken because the building and its morale were viewed to be in crisis, and some modeling or teaching for [Ulichny] was needed in light of the situation after [her] three years in the district.” (Id.) When asked by Ulichny’s counsel what Flynn wanted Ulichny to do if she disagreed with him or the Board on a given matter, Flynn stated that he would prefer that Ulichny express her disagreement to him directly and carry out the particular directive to the best of her ability. (Id.) Flynn also stated that “[i]f disagreements mount with superordinates, and are not tolerable in the eyes of the middle level manager (principal), they have no choice but to leave and assume a middle level management or superintendent role elsewhere.” (Id.) Ulichny’s attorney closed the meeting by stating that the proposed changes “appeared to be a system where [Flynn] was the Principal and [Ulichny] ... an Assistant Principal,” and further that he “was not really confident things would work out this way.” (Id.) The parties dispute the specifics of what actually occurred once the 1998-99 school year began, so the Court sets forth the following facts in the light most favorable to Ulichny. At the beginning of the school year, Flynn moved his office into the Intermediate School, directly across the hall from Ulichny’s office. (PFOF at ¶ 122.) Flynn presided over the first faculty meeting on August 21st, during which he told staff that he would be handling all discipline at the Intermediate School and that he would perform all teacher supervision and evaluations, though he might delegate some of these duties to Ulichny at a later date. (PFOF at ¶ 123.) A subsequent memo to school staff stated that staff members could approach either himself or Ulichny with questions or concerns, but also indicated that he was their “direct supervisor.” (Ulichny Aff., Ex. 71.) Going forward, Flynn assumed the main duties of School Principal. (PFOF at ¶ 125.) For example, he hired a teacher for the school without conferring with Ul-ichny. (Id.) He conducted staff meetings without notifying Ulichny of the meetings or advising her afterward of what was accomplished. (Id.) He selected mentors for new teachers without involving Ulich-ny. (Id.) He dealt directly with staff, parents and students regarding day-to-day issues at the school; Ulichny had to refer queries from parents and staff to Flynn. (PFOF at ¶ 127.) Ulichny’s playground, lunch room, hallway and bus monitoring duties accounted for almost four hours of her work day. (PFOF at ¶ 128.) It is unclear what specific duties filled in the remaining hours. However, Ulichny’s work report for the week of August 28, 1998 indicates that she also interviewed candidates for the positions of substitute teacher and “EEN aide,” met with teachers regarding “study hall,” “enrichment” and “TAG,” met with the teacher assistants, visited all classrooms, met several times with Flynn, and participated in a meeting regarding the records of new students at the school. (Flynn Aff., Ex. SS.) The same report indicated a listing of events for the week of August 31 — September 4, 1998, which included an administrative meeting, a sixth grade back to school night, a meeting of the Advisory Committee, followed by two vacation days (presumably the Labor Day holiday). (Id.) Ulichny worked only four more days following the Labor Day holiday. On September 10, 1998, a student questioned Ul-ichny as to why she was still working at the school if she was no longer the principal. (PFOF at ¶ 131.) At the end of that same day, Ulichny asked Flynn whether the current division of responsibilities would continue. (PFOF at ¶ 132.) Flynn replied that they would. (Id.) Ulichny called in sick the next day. (PFOF at ¶ 133.) At Flynn’s request, Ulichny produced a physician’s note — dated September 21, 1998 — which advised that Ulichny was suffering from an unspecified “medical illness” and that she was “to remain off work until [her] condition is improved.” (PFOF at ¶ 134; Flynn Aff., Ex. UU.) Ulichny was officially absent from work due to illness from September 11 — November 19, 1998. (DFOF at ¶ 113; PR at ¶ 113.) On September 30, 1998, Flynn sent Ulichny forms to apply for a medical leave of absence. (DFOF at ¶ 116; PR at ¶ 116.) Ulichny responded by stating that she was not requesting leave under the Family Medical Leave Act. (DFOF at ¶ 117; PR at ¶ 117.) On October 19, 1998, Ulichny’s lawyer sent a letter to the District alleging that the District had constructively terminated Ulichny’s employment as Principal and her corresponding contract. (Flynn Aff., Ex. XX.) Enclosed was a draft of the complaint for the lawsuit Ulichny intended to file. (Id.) This lawsuit was filed one month later. II Under Rule 56(c), summary judgment is proper “if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law.” Celotex Corp. v. Catrett, 477 U.S. 317, 322, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). Summary judgment is no longer a disfavored remedy. “Summary judgment procedure is properly regarded not as a disfavored procedural shortcut, but rather as an integral part of the Federal Rules as a whole, which are designed ‘to secure the just, speedy and inexpensive determination of every action.’ ” Id., at 327, 106 S.Ct. 2548. It “can be a tool of great utility in removing factually insubstantial cases from crowded dockets, freeing courts’ trial time for those that really do raise genuine issues of material fact.” United Food and Commercial Workers Union Local No. 88 v. Middendorf Meat Co., 794 F.Supp. 328, 330 (E.D.Mo.1992). Thus, “the plain language of Rule 56(c) mandates the entry of summary judgment, after adequate time for discovery and upon motion, against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Celotex, 477 U.S. at 322, 106 S.Ct. 2548. “[T]he mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment; the requirement is that there be no genuine issue of material fact.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247-48, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986). While a material fact is one that is “outcome determinative under the governing law”, Whetstine v. Gates Rubber Co., 895 F.2d 388, 392 (7th Cir.1990), a genuine issue as to that material fact is raised only “if the evidence is such that a reasonable jury could return a verdict for the nonmov-ing party.” Anderson, 477 U.S. at 248, 106 S.Ct. 2505. The question whether a material issue of fact is genuine necessarily requires “some quantitative determination of sufficiency of the evidence.” Childress, A New Era for Summary Judgments: Recent Shifts at the Supreme Court, 116 F.R.D. 183, 186 (1987). “Of course, a court still cannot resolve factual disputes that could go to a jury at trial, ... [b]ut no longer need the trial court leave every sufficiency issue for trial or a later directed verdict motion.” Id. “A district judge faced with [a summary judgment motion] must decide, subject of course to plenary appellate review, whether the state of the evidence is such that, if the case were tried tomorrow, the plaintiff would have a fair chance of obtaining a verdict. If not, the motion should be granted and the case dismissed.” Palucki v. Sears, Roebuck & Co., 879 F.2d 1568, 1572-73 (7th Cir.1989) (citations omitted). Thus, a party opposing summary judgment “must do more than simply show that there is some metaphysical doubt as to the material facts.” Matsushita Electric Industrial Co. v. Zenith Radio Corporation, 475 U.S. 574, 586, 106 S.Ct. 1348, 89 L.Ed.2d 538 (1986). “[A] party must produce ‘specific facts showing that there remains a genuine issue for trial’ and evidence ‘significantly probative’ as to any [material] fact claimed to be disputed.” Branson v. Price River Coal Company, 853 F.2d 768, 771-72 (10th Cir.1988). “If the evidence is merely colorable, or is not significantly probative, summary judgment may be granted.” Anderson, 477 U.S. at 249-50, 106 S.Ct. 2505. Nor may “[a] party to a lawsuit ... ward off summary judgment with an affidavit or deposition based on rumor or conjecture. ‘Supporting and opposing affidavits shall be made on personal knowledge, ....’” Palucki, 879 F.2d at 1572 (7th Cir.1989). Such principles insure that shmmary judgment is utilized “when it can be shown that a trial would serve no useful purpose.” Windham v. Wyeth Laboratories, Inc., 786 F.Supp. 607, 610 (S.D.Miss.1992). Ill Ulichny raises several federal and state law claims in this suit, but the Court focuses first (and exclusively) on the federal claims as they provide the basis for the Court’s jurisdiction. Construed favorably, Ulichny’s pleadings allege that defendants’ actions violated the 14th Amendment to' the Federal Constitution by depriving her of two identifiable property interests without due process of law: (1) Her right to perform the duties typically assigned to a public school principal in Wisconsin; and (2) her right to public employment per se, with a corresponding right not to be constructively discharged from her public employment. Ulichny also claims that defendants’ actions violat- . ed the 14th Amendment by depriving her of a liberty interest in her occupation without due process of law. Finally, Ul-ichny claims the defendants’ conspired to deprive her of the foregoing liberty and property interests. On summary judgment defendants argue, inter alia, that Ulichny has no property right to perform the duties typically assigned to a public school principal, she was not constructively discharged but rather voluntarily resigned, neither the School District nor any individual Board member or administrator publicly communicated any stigmatizing information concerning Ulichny, the individual defendants enjoy qualified immunity from liability for their actions, and there is no evidence of a conspiracy. The Court addresses these issues as follows. A. DENIAL OF PROPERTY INTERESTS The 14th Amendment to the Federal Constitution provides that no State may “deprive any person of life, liberty, or property, without due process of law....” It is important to keep in mind, however, that “[pjroperty interests ... are not created by the Constitution.” Board of Regents of State Colleges v. Roth, 408 U.S. 564, 577, 92 S.Ct. 2701, 33 L.Ed.2d 548 (1972). “Rather they are created and their dimensions are defined by existing rules or understandings that stem from an independent source such as state law— rules or understandings that secure certain benefits and that support claims of entitlement to those benefits.” Id. Thus, property interests are most frequently found to arise from rights created by state statutes, state or municipal regulations or ordinances, and contracts with public entities (especially employment contracts with public entities). But these are not the exclusive sources of property interests. “[P]roperty interests subject to procedural due process protection are not limited by a few rigid, technical forms.” Perry v. Sindermann, 408 U.S. 593, 601, 92 S.Ct. 2694, 33 L.Ed.2d 570 (1972). “Rather, ‘property denotes a broad range of interests that are • secured by ‘existing rules or understandings.’ ” Id. “A person’s interest in a benefit is a ‘property’ interest for due process purposes if there are such rules or mutually explicit understandings that support his claim of entitlement to the benefit and that he may invoke at a hearing.” Id. For example, a property interest need not be based on an explicit statutory or contractual provision. Such explicit provisions “may be supplemented by other agreements implied from ‘the promisor’s words and conduct in the light of the surrounding circumstances.’ ” Id. at 602, 92 S.Ct. 2694. All that said, [t]o have a property interest in a benefit, a person clearly must have more than an abstract need or desire for it. He must have more than a unilateral expectation of it. He must, instead, have a legitimate claim of entitlement to it. Roth, 408 U.S. at 577, 92 S.Ct. 2701. 1. Duties of Public School Principal Ulichny argues that she had a property interest in performing all of the duties normally expected of a school principal in Wisconsin. She bases this claim on certain language in her contract and the Wisconsin statutes, as well as an alleged “mutual understanding” between herself and the School District. The Court disagrees. Ulichny cites two provisions in her contract as giving rise to a property interest in performing the normal duties of a school principal. The first, quoted supra, obligated Ulichny “to devote full time to the duties and responsibilities normally expected of the Principal’s position during the term of this contract,.... ” The second, also quoted supra, obligated Ulichny “to perform at a professional level of competence the services, duties and obligations required by the laws of the State of Wisconsin and the rules, regulations and policies of the Board.... ” Consistent with the latter provision, Ulichny turns to various Wisconsin statutes to flesh out the “normal” and/or “required” duties of a school principal. The statutes she points to are a hodgepodge of very specific bequests of authority and/or duties governing very specific situations, ie., the removal of a pupil from class, the reporting of indigent children, the suspension of a pupil, and the handling/reporting of communicable diseases. See, Wis. Stats. §§ 118.18, 188.17, 120.13(l)(b) & 252.21. Such isolated provisions hardly set forth or give rise to a property interest in performing the broad range of “normal” or “required” duties Ulichny alleges she was entitled to perform as principal. This is particularly so when one considers the single statutory provision that actually does address the general duties of a school principal. That statute leaves the specification and assignment of such duties to the discretion of the district administrator employed by a particular school district: (3) The principal shall perform such administrative and instructional leadership responsibilities as are assigned by the district administrator subject to the rules, regulations and approval of the school board. Wis. Stat. § 118.24(3). Thus, the Wisconsin statutes do not support the existence of a principal’s property interest in performing specific duties. Neither does the contract’s reference to “the duties and responsibilities normally expected of the Principal’s position.... ” This provision, placed within the “RESPONSIBILITIES” section of the statute, simply sets forth what Ulichny’s obligations were under the contract. It does not place a reciprocal obligation on the Board or prevent it — or the district administrator acting with the Board’s authority — from determining what the precise nature of Ulichny’s duties would be. This interpretation is consistent with Judge Reynolds’ decision in Terry v. Woods, 803 F.Supp. 1519 (E.D.Wis.1992). There, a Wisconsin school principal who had been temporarily suspended (with pay) tried to argue that his contract created a property interest in going to work and performing his duties as principal. Judge Reynolds disagreed, explaining that the explication of a principal’s duties in a contract did not create such an interest: The court concludes that the circumstances surrounding Terry's employment do not indicate that he was “entitled” to go to work. Most importantly, Terry’s contract cannot be read as conferring any such entitlement. The consideration flowing to him under the contract is limited to his salary and certain fringe benefits of an economic nature. Although both the contract and state law require Terry to perform certain duties, that requirement does not directly impose any obligation upon [the School District]. Terry may have reasonably expected that he would be able to do his work, but an expectation by itself does not create a property interest. Terry, supra, at 1524. This interpretation of the contract is further made clear by two other provisions therein. The first, cited and relied upon by Ulichny, supra, requires Ulichny “to perform ... the services, duties and obligations required by ... the rules, regulations and policies of the Board.... ” The second provision is found within the “RESPONSIBILITIES” section of the contract — the only such provision purporting to set forth a Board obligation — and states that “[t]he Board shall provide the Principal with a written job description of [her] services, duties and obligations.” These two provisions certainly imply that the Board has the authority and discretion to determine the specific nature and scope of Ulichny’s job duties, especially when read in conjunction with the similar discretion accorded school districts and/or their administrators under § 118.24(3). Finding little support for a property interest in the express words of her contract or the Wisconsin statutes, Ulichny tries to create a dispute of fact through the submission of an affidavit from Charles Hilston (“Hilston”), a proposed expert witness in the operation of Wisconsin school districts. Hilston offers a number of opinions, but relevant here are: (1) His opinion that the normal and/or primary duties of a school principal in Wisconsin include supervising and evaluating professional and support staff, enforcing the discipline of students, recruiting, screening, hiring, training and assigning professional and support staff, and conducting staff meetings; and (2) his opinion that when a principal and a school district in Wisconsin enter into a contract, it is understood that the principal has the right to perform the latter duties and the school district cannot simply reassign the principal to a lesser position and/or lesser duties. (Hilston Aff at ¶¶ 22-23; Plaintiffs Brief in Opposition at 64-66.) Ulichny argues that Hilston’s affidavit suggests the existence of a “mutually explicit understanding” between school principals and school districts in Wisconsin that a principal has a right to perform the normal duties of a school principal (as described by Hilston). The Court does not attach such significance to Hil-ston’s affidavit. First, the affidavit asserts the existence of an implicit understanding that runs contrary to both the express language of the contract and the relevant Wisconsin statute. The contract and § 118.24(3) grant the School Board and Flynn (as District Administrator) broad discretion to determine the responsibilities and duties of their various principals and required Ulichny to do whatever the Board and/or Flynn told her to do in the exercise of that discretion. Hilston’s testimony simply ignores or obfuscates these express provisions and asserts in their place an unwritten and unspoken “understanding” between, not just these particular litigants, but principals and school districts across the State of Wisconsin. The Court will not allow the contract and governing statute to be rewritten in this fashion. Second, even if the Court were inclined to allow Hil-ston’s testimony to call into question the express language of the contract and § 118.24(3), it would only do so on the basis of strong factual evidence supporting Hilston’s opinion that the alleged “understanding” actually exists. There is no such evidence in this record. Hilston’s affidavit does not identify or state that he reviewed or compiled any historical data concerning the uniformity of the duties assigned to school principals across Wisconsin, or more importantly, the frequency with which Wisconsin school principals are reassigned to lesser positions and/or their duties decreased. Certainly such information is obtainable, or if it is not, then what factual evidence supports Hilston’s opinions? His general experience in the industry? While the Court acknowledges that Hilston’s experience in the industry is substantial, such experience alone is not enough to allow a reasonable jury to conclude that Ulichny’s contract and § 118.24(3) do not mean what they seem to say. Finally, the Court’s decision is consistent with the majority of courts considering the issue and holding that a public employee has no property interest in a particular assignment or job duty, as opposed to his or her employment per se. See, Lewandowski v. Two Rivers Public School District, 711 F.Supp. 1486, 1495-96 (E.D.Wis.1989)(and cases cited therein). The few exceptions to this rule are cases involving an express contractual or statutory provision stating that the class of employee at issue could not be demoted or reassigned except under specified circumstances and procedures. See e.g., Hatcher v. Board of Public Education and Orphanage for Bibb County, 809 F.2d 1546, 1550-52 (11th Cir.1987). There is no such provision or statute here. Moreover, the 7th Circuit has repeatedly expressed its doubts as to whether a transfer, reassignment or even demotion of a public employee that involves no diminution in salary can ever give rise to a 14th Amendment claim. See, Parrett v. City of Connersville, 737 F.2d 690, 693 (7th Cir.1984); Greenberg v. Kmetlco, 840 F.2d 467, 475 (7th Cir.1988); Lyznicki v. Board of Education, 707 F.2d 949, 951 (7th Cir.1983). It has also implied that such a claim could only exist, if at all, under circumstances involving an express contractual or statutory provision establishing the asserted right to the particular job assignment, and could not be based on an implied or non-contractual understanding between the parties. See, Gustafson v. Jones, 117 F.3d 1015, 1020 (7th Cir.1997). Ulichny asserts, at best, such an implied understanding, one that contradicts the language and spirit of the express contractual and statutory provisions. Accordingly, for all of the reasons expressed above, the Court concludes that Ulichny did not have a property interest in performing the duties normally expected of a school principal in Wisconsin. Having no such property interest, she cannot claim the protections of the 14th Amendment as a challenge to the proposed and/or actual revision of her job duties. 2. Constructive Discharge Ulichny also asserts a property interest in her employment per se, which was allegedly deprived when Flynn and the School District constructively discharged her by revising her job duties and thus making her working conditions so intolerable that she was compelled to quit. It is well-established that a public employee with a term contract that can only be terminated for cause has a property interest in continued employment for the duration of the contract which is protected by the 14th Amendment. See, Thornton v. Barnes, 890 F.2d 1380, 1386 (7th Cir.1989). It is also well-established that a public employer who makes the working conditions of such an employee so intolerable that he or she is compelled to quit prior to the expiration of the contractual term deprives the employee of property within the meaning of the 14th Amendment. See, Parrett, 737 F.2d at 694. Accordingly, if Ulichny could create a genuine issue of material fact as to whether or not she was constructively discharged, this particular claim might survive summary judgment. The Court concludes, however, that the record is insufficient in this regard. “A constructive discharge occurs when the employer makes conditions so intolerable that a reasonable person in the employee’s posi