Application of the due process clause of the Fourteenth Amendment to dismissal of public employees has become clarified through such recent federal court litigation as "Loudermill v. Cleveland Board of Education" in 1981, which followed the Supreme Court precedent set in 1972 in "Board of Regents v. Roth." The threshold question in due process is whether the individual has a liberty or a property interest at stake in continued employment. Although the Court dismissed Loudermill's complaint and that of another school employee, Donnelly, the central finding is that both employees had a property interest. School boards must provide tenured and nontenured employees reasons for discharge and an opportunity to respond. Most Americans can be considered "employees-at-will," or noncertified employees who are not covered by a collective bargaining agreement and are subject to the century-old doctrine that employment for an unspecified period of time permits termination at any time. The judicial trend to protect against arbitrary termination of at-will employees such as Loudermill and Donnelly reflects society's increasing expectations of fair treatment--basically limiting the employer's right to dismiss except for "cause." Because the concept of due process is flexible, certain procedural issues remain unresolved. (CJH)