
Quoting
Cleveland v. Arpaio, Dist. Court, D. Arizona 2013 (citations omitted)
An action for damage to reputation ordinarily "lies . . . in the tort of defamation, not in [42 U.S.C. §] 1983."... "To recover damages for defamation under § 1983, a plaintiff must satisfy the `stigma-plus test.'"... "Under that test, `a plaintiff must allege loss of a recognizable property or liberty interest in conjunction with the allegation of injury to reputation.'" .... The injury must be to a "previously recognized right or status.".... Further, "the `stigma-plus test' requires that the defamation be accompanied by an injury directly caused by the Government, rather than an injury caused by the act of some third party [in reaction to the Government's defamatory statements]." Id. at 1320 (injuries caused by third party's response to government statements not cognizable under § 1983). "There are two ways to state a cognizable § 1983 claim for defamation-plus: (1) allege that the injury to reputation was inflicted in connection with a federally protected right, or (2) allege that the injury to reputation caused the denial of a federally protected right.".... Plaintiff alleges an injury to his reputation based on the actions of others in reaction to allegedly defamatory statements by governmental statements. He does not allege facts to support that any injury to reputation was inflicted in connection with a federally protected right. Nor does he allege facts to support that the injury to his reputation caused the denial of a federally protected right.