What is the test for making a stigmatizing statement be made public?

MultiRegion, United States of America

The following excerpt is from Walker v. Fitzpatrick, No. 19-963 (2nd Cir. 2020):

Patterson v. City of Utica, 370 F.3d 322, 330 (2d Cir. 2004) (citations and internal quotation marks omitted). The stigmatizing statement must be made public to support such a claim. See id.

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