In '''''Paul v. Davis,''''' 424 U.S. 693, 701-02 (1976), then-Justice [[William Rehnquist]] wrote for a divided [[U.S. Supreme Court]] that "[d]amage to [[reputation]] alone is not actionable under ยง 1983 unless accompanied by injury to "some more tangible interests."
This holding has frequently been distinguished and questioned by lower courts.