David Rivkin, Edward Rivkin, and Judith Rivkin, T/A Galaxy Manor, a New Jersey Partnership, Plaintiffs-Appellants…

Summary

The Supreme Court of New Jersey affirmed the Appellate Division, holding that the Rivkins could not recover under 42 U.S.C. §1983 because the State provided a plain, adequate, and timely post‑deprivation remedy and the board member's bias did not rise to a substantive due process violation. The Court also concluded that the alleged conduct was procedural, not substantive, due process, and that the state remedy was sufficient despite not providing attorney's fees.