Huimin Song, et al. v. County of Santa Clara, California, et al.

Should certiorari be granted to review an issue of national importance regarding the extent of procedural due process under the Fourteenth Amendment due to employees whose employer exercises self-help to recoup mistakenly overpayment directly from the employee’s paycheck?

Do prior decisions of this Court which require procedural due process under the Fourteenth Amendment to be appropriate and meaningful, require an employee from whom an employer takes by an act of self-help an excessive amount of payroll overpayment have at least a non-adversarial hearing before a third party?

Do perfunctory elements of notice and the right or opportunity to be heard satisfy procedural due process under the Fourteenth Amendment regarding pre-deprivation and post-deprivation taking of private property, i.e, the earned wages of an employee?

Did the Ninth Circuit correctly decide Respondent provided adequate due process in this case by disregarding the detailed factual findings of the district court to the contrary?

Did the Ninth Circuit improperly overrule the district court’s denial of Respondent’s renewed motion for judgment as a matter by ignoring the district court’s detailed factual finding Respondent had a written policy regarding the matters in issue concerning municipal liability under §1983?