10.2190/2K68-VHB3-5D8F-2F60 2K68VHB35D8F2F60 6 The Murky World of Due Process in Disciplining Public Employees: The Supreme Court's Ruling in <i>Gilbert v. Homar</i> 247 261 20020509 20020509 20020509 20020509 2K68VHB35D8F2F60.pdf http://baywood.metapress.com/link.asp?target=contribution&id=2K68VHB35D8F2F60 3 Robert D. Lee Jr. Pennsylvania State University The Supreme Court ruled in <i>Gilbert v. Homar</i> (1997) that a public employer need not give an employee notice and hearing before suspending that employee without pay. The Court held three factors were to be considered in determining what due process was to be afforded: the employee's interest, government's interest, and the risk of erroneous deprivation through the procedures used. The <i>Homar</i> case raises issues of what constitutes procedural due process and substantive due process as pertaining to property rights and due process as it relates to the right of liberty. The implications of the <i>Homar</i> decision are explored.