In the case of Logan v. Zimmerman Brush Co., 1981, the U.S. Supreme Court ruled that a state agency's failure to convene a timely conference on an employee's discrimination complaint constituted a denial of due process under the Fourteenth Amendment. The plaintiff, George Logan, filed a racial discrimination claim against his employer with Illinois' Fair Employment Practices Commission (FEPC). However, FEPC failed to hold required preliminary fact-finding conference within 120 days as mandated by state law and dismissed Logan’s complaint as untimely. The court held that because this procedural error was not attributable to any action or inaction on part of Logan himself but rather resulted from negligence by FEPC officials who were acting under color of state law; it amounted to deprivation of property without due process.

In the dissenting opinion for Logan v. Zimmerman Brush Co., Justice Powell, joined by Chief Justice Burger and Justice Rehnquist, argued that the majority's decision expanded the scope of due process rights beyond what was intended by previous rulings. They contended that while a person has a right to an opportunity to be heard before being deprived of property or liberty, this does not necessarily mean they have a constitutional right to procedural mechanisms like those provided under Illinois' Fair Employment Practices Act (FEPA). The dissenters believed that Logan had no entitlement to these procedures because his claim did not involve any fundamental interest protected by substantive due process nor any suspect classification triggering strict scrutiny review. Moreover, they asserted that even if there were such an entitlement, it would only require minimal procedural safeguards rather than FEPA’s elaborate adjudicatory proceedings. Finally, they disagreed with the majority's view on causation: in their perspective, it was not state action but private discrimination which caused Logan’s alleged injury.