With no explanation, chose the best option from "A", "B", "C" or "D". City of Independence, 445 U.S. 622, 633, n. 13, 100 S.Ct. 1398, 63 L.Ed.2d 673 (1980) (explaining that “the due process right to a hearing” is triggered when the dismissal of a government employee with no property interest in his or her position is accompanied by charges or allegations that might seriously damage his or her standing and associations in the relevant community); Board of Regents v. Roth, 408 U.S. 564, 573, 92 S.Ct. 2701, 33 L.Ed.2d 548 (1972) (suggesting that where the state-occasioned deprivation of a government job to which an individual has no claim of entitlement imposes on him or her “a stigma or other disability that fore-closets] his [or her] freedom to take advantage of other employment opportunities,” the Due Process Clause is implicated); Hill, 455 F.3d at 238 (<HOLDING>). Burns alleges that she had

A: holding that a public employee who is defamed in the course of being terminated or constructively discharged satisfies the stigmaplus test even if as a matter of state law he or she lacks a property interest in the job that he or she lost
B: holding that a public employee who can be discharged only for cause is entitled to at least some informal due process before he can be terminated
C: holding that a defendants pro se status may be terminated if he or she has demonstrated disruptive behavior or used the right as a tactic for delay disruption distortion of the system or manipulation of the trial process
D: holding that a person has standing to bring suit under the civil rights act if she or he can show that she or he was punished for trying to vindicate the rights of minorities
A.