Two 1972 Supreme Court decisions--Board of Regents v. Roth and Perry v. Sindermann--established the nonrenewal of teacher appointments. These two decisions presented two questions: Does a nontenured teacher have a constitutional right to be told the reasons for nonreappointment; and, if so, does he or she have a right to a hearing. This paper discusses the two cases with special attention to those situations in which a "liberty" interest (for example, a damaged reputation) has been identified by the courts and the school has been directed to provide notice and a hearing, and those situations in which courts have said no liberty interest has been violated and the school may decline to reappoint a teacher without any procedural observances. The conclusion states that denial of a liberty interest is rare and occurs only when such an interest can be identified (such as through public accusations), or when such charges are placed in a personnel file that is open to the public. (Author/LD)