Is a government employee entitled to sue for unfair dismissal or demotion if they are defamed in the course of their employment?

Baden v. Koch, supra, also involved a due process claim by a government employee. In Baden, the plaintiff alleged that he had been defamed in the course of being demoted from a probationary position as New York City's chief medical examiner back to his position as deputy medical examiner. We ruled that the plaintiff "asserted at best a weak liberty interest." Id. at 831. We did not suggest that the plaintiff's liberty interests would have been implicated if he had been defamed outside the context of dismissal or demotion from his government job.