ORDER

WILLIAM H. STEELE, District Judge.

This matter comes before the Court on Defendants City of Mobile, Sandy Stimpson, James Barber and Joseph Kennedy's Motion for Summary Judgment (doc. 36); defendant Donald Dees' Motion for Summary Judgment (doc. 37); defendant Mobile County Personnel Board's Motion for Summary Judgment (doc. 39); and Plaintiff's Motion for Partial Summary Judgment Against All Defendants (doc. 44). All four Motions have been briefed and are now ripe for disposition.1

I. Nature of the Case.

Plaintiff, Carla Longmire, was employed by the City of Mobile Police Department as a Police Captain. In this capacity, she was a Mobile County Merit System Employee whose employment was subject to, and governed by, the rules of the Mobile County Personnel Board. (Complaint, ¶¶ 1, 7.) Longmire brings this action against six governmental defendants, alleging procedural due process violations in connection with certain disciplinary proceedings conducted in 2013 and 2014, pursuant to which she was demoted from the rank of Captain to that of Lieutenant. In particular, Longmire has named four municipal defendants, to-wit, the City of Mobile, Alabama (the "City"); Sandy S. Stimpson, Mayor of the City of Mobile ("Mayor Stimpson"); James Barber, Chief of the Mobile Police Department ("Chief Barber"); and Joseph D. Kennedy, the former Assistant Chief of the Mobile Police Department ("Assistant Chief Kennedy") (collectively, the "City Defendants"). Also named as defendants are the Mobile County Personnel Board (the "MCPB") and Donald Dees, the MCPB's former Personnel Director.

In Count One of the Complaint, Longmire asserts a cause of action under 42 U.S.C. § 1983 for violation of procedural due process rights guaranteed by the Fourteenth Amendment. Plaintiff's stated theory of liability is that "[b]y demoting Plaintiff without following mandatory and non-discretionary Mobile County Merit System due process procedures, Defendants deprived the Plaintiff of her property rights interest in her job as a county merit system employee without due process of law." (Complaint, ¶ 13.) Count One is littered with allegations that defendants conducted Longmire's disciplinary proceedings in a manner that violated the provisions of MCPB Rule 14.3(a), as well as certain other rules established by the Mobile County Personnel Board. (Id., ¶¶ 14, 16, 18, 19, 23, 24.) Longmire's § 1983 claim against all defendants is summarized in the Complaint as follows: "The provisions of MCPBR 14.3(a) mandated certain prescribed timeframes and due process procedures. The Defendants knowingly failed to abide by them and continue to do so even through the date of this filing." (Id., ¶ 24.) After the City Defendants made the disciplinary decision, Longmire alleges, the MCPB "upheld the demotion of Longmire and did so in violation of its own due process rules and the Constitution of the United States." (Id.)

Count Two of the Complaint is captioned "Due Process — (State based claim)," and alleges that the demotion decision "unlawfully deprived Longmire of her right to due process guaranteed under the Alabama Constitution of 1901, Article 1, §§ 6, 13, 22, among other applicable sections, including the provisions of the `Act' that created the MCPB, the Rules of the Mobile County Personnel Board; including well-settled case law decisions." (Id., ¶ 27.) Thus, Count Two is a due process claim rooted in the Alabama Constitution, rather than the U.S. Constitution, but is otherwise analogous to and coextensive with Count One.

II. Factual and Procedural Background.2

A. The December 10 Notice.

On December 10, 2013, a three-page document captioned "Mobile Police Department Disciplinary Trial Board Notice" and signed by defendant Assistant Chief Kennedy was hand-delivered to Longmire. (Doc. 13-4.) The Notice purported to be from defendant Mayor Stimpson (listed as "Designated Appointing Authority") and reflected that administrative disciplinary action (consisting of "demotion, suspension not to exceed thirty (30) days, or dismissal") was contemplated against Longmire.

On its face, the December 10 Notice delineated two charges against Longmire, both pursuant to MCPB Rule 14.2's prohibition on "conduct unbecoming an employee in the public service." (Doc. 13-4.) Charge I included a "Specification" in the Notice in the following terms:

(Id. at 2.) Similarly, the December 10 Notice included the following Specification of the factual underpinnings of Charge II:

(Id. at 3.)

The December 10 Notice alerted Longmire that a "non-adversary Trial Board Hearing" would be convened at Police Headquarters concerning these charges at 9:00 a.m. on December 16, 2013. During this hearing, the Notice continued, Longmire "will be given an opportunity to enter a plea relative to the stipulated alleged charges and specifications. You will be afforded a chance to respond verbally to the alleged charges if you so desire." (Id. at 1.) The Notice further apprised Longmire of the following: (i) "you are entitled to have legal counsel and/or a representative present at the hearing as an observer during any questioning or statement(s) made by you;" (ii) "you may submit a list of witnesses who can give direct testimony on your behalf that is relevant to the alleged charges and specifications;" (iii) any list of such witnesses must be "presented to the Department's legal advisor within three (3) working days upon receipt of this Notice;" and (iv) in the event that discipline were imposed, Longmire would "have a right of appeal as granted by the Rules of the Mobile County Personnel Board." (Id.)

B. The Pre-Deprivation Hearing.

The Trial Board Hearing was convened as scheduled on December 16, 2013, before a Trial Board Committee consisting of Assistant Chief Kennedy and two other Mobile Police Department officials. (Doc. 18-2, at 2.)3 Also present was the City of Mobile's Assistant City Attorney, Wanda B. Rahman. (Id.) Mayor Stimpson (the ultimate decision maker) did not attend. Longmire was present, and brought with her a non-attorney representative named Joanne Ming. (Id. at 4.) At the outset of the hearing and after being placed under oath, Longmire acknowledged both receipt of the December 10 Notice and awareness of her due process rights. (Id. at 5.) She initially entered a plea of "[n]ot guilty with an explanation" as to Charge I and "[n]ot guilty" as to Charge II. (Id. at 6.) Longmire then exited the hearing room, and Officer Latham (the subordinate with whom Longmire was charged with being involved in an intimate relationship) entered and pleaded guilty to charges of conduct unbecoming, truthfulness during investigation and disobedience of orders based on his having had private meetings and sexual intercourse with Longmire at her apartment during duty hours. (Id. at 8-10.)

At that time, Officer Latham left the room and Longmire returned to face questioning by Assistant City Attorney Rahman. During such examination, Longmire admitted having had sexual relations with Officer Latham at her apartment during her lunch break while he was on duty. (Doc. 18-2, at 11.)4 She also admitted that Officer Latham had come to her apartment to visit her on multiple other occasions during duty hours. As the hearing proceeded, Longmire indicated that she wished to change her plea and "Plead guilty" to Charge I. (Id. at 22.) Assistant Chief Kennedy later asked, "But you want to plead guilty to the first charge?" (Id. at 34.) Longmire responded in the affirmative. (Id.) By the end of the hearing, Longmire conceded that allowing Officer Latham to come to her private dwelling while he was on duty was not "proper supervision," and on that basis she changed her plea to guilty on Charge II, as well. (Id. at 43.)

When Longmire's testimony concluded, she left the hearing room. The Trial Board then received testimony from four other witnesses outside of Longmire's presence, to-wit: Officer Latham, Sergeant David Wayne Ellzey, Sergeant Michael Barber, and Chaplain Jerry Brown. Longmire did not identify or ask to call any witnesses of her own.

On December 17, 2013, a letter signed by Mayor Stimpson on behalf of the City was issued to Longmire with the subject line "OFFICIAL NOTICE OF DEMOTION." (Doc. 13-5.) Mayor Stimpson's letter recounted the Trial Board hearing that had occurred the previous day, then stated as follows:

(Id.) The December 17 Letter concluded by apprising Longmire of her right to appeal her demotion pursuant to the rules of the Mobile County Personnel Board. (Id.)5

C. The Post-Deprivation Hearing.

Longmire timely filed a notice of appeal from Mayor Stimpson's demotion decision on or about December 20, 2013. (Dees Aff. (doc. 13-1), ¶ 4; doc. 13-7, at 1.) In accordance with that appeal, defendant Donald Dees (who was then the Personnel Director of the MCPB) confirmed that Longmire had been furnished with written notice of the pre-disciplinary hearing at least 24 hours in advance, that the notice set forth the factual allegations underlying the contemplated disciplinary action, that Longmire received an opportunity to respond to the charges at the hearing, that Mayor Stimpson demoted her following the hearing, that Longmire had been given written notice of her demotion, and that her notice of appeal was timely. (Dees Aff., ¶ 4.) After confirming these circumstances, Dees scheduled the matter for a de novo hearing before the MCPB. (Id.)

Longmire's appeal was heard by the MCPB on March 6, 2014. Longmire attended the Personnel Board hearing, where she was represented by counsel of her choosing, Carroll Ogden. (Id., ¶ 5; doc. 13-6.) Also present were five members of the MCPB, attorney Rahman representing the City, and attorney James Brandyburg representing the MCPB. (Doc. 13-6, at 2.) Brandyburg presided over the hearing, including calling witnesses and deciding evidentiary matters. Before any testimony was presented, Longmire's counsel summarized three motions to dismiss that had been submitted, all alleging procedural improprieties relating to the December 16 proceedings. In particular, Longmire's counsel described various purported violations of MCPB Rules 14.3(a) and Rule 14.5, to-wit: (i) Longmire was not "afforded a pre-disciplinary hearing in front of the person charged with final decision-making authority" (i.e., Mayor Stimpson); (ii) the December 10 Notice did not inform Longmire "that she has a right to submit either a verbal statement or a written statement . . . or really none at all . . . to the Appointing Authority," but instead cited only her right to make a "verbal" statement; and (iii) Dees failed to comply with the requirements of MCPB Rule 14.5 that he review the material for compliance with Rules 14.3 and 14.4 before setting the matter for MCPB hearing. (Doc. 13-6, at 10-12.) Longmire's counsel termed this a "very serious situation" that had deprived Longmire of due process of law. (Id. at 13.) After hearing argument from the City's attorney (Rahman), Brandyburg recommended that the MCPB deny Longmire's motions to dismiss. (Id. at 13-14.) The Board adopted Brandyburg's recommendation and denied the motions. (Id. at 14-15.)6

As the hearing proceeded, the City called two witnesses to testify in favor of its demotion decision. The first, Roy Bruce Hodge, Jr., was a Mobile Police Department lieutenant who explained his investigation of allegations of on-duty sexual contact between Longmire and Officer Latham. (Id. at 20-22.) Longmire's counsel objected "to any testimony until you put the mayor on the stand . . . to establish what he knew and what he didn't know at the time he made his decision." (Id. at 23.) Brandyburg overruled the objection and indicated, "I have already ruled that the mayor should not be called as a witness in this proceeding." (Id.) The City's second witness, Assistant Chief Kennedy, testified about various topics, including the December 16 hearing and Longmire's entry of guilty pleas at that time.7 Assistant Chief Kennedy indicated that the Trial Board had unanimously agreed that demotion was the appropriate punishment, given that Longmire and Officer Latham's conduct was "the worst thing I can possibly imagine" and "the most egregious act that I can think that you would do." (Id. at 68-69.) He explained that the Trial Board "didn't fire her because probably of her length of service" and her relatively unblemished disciplinary record. (Id. at 69-70.) On cross-examination, Assistant Chief Kennedy elaborated that Longmire's discipline was more severe than Officer Latham's because she was his supervisor and "the person in charge is surely, you know, more at fault than the under officer." (Id. at 79.)

After the City rested, Longmire's counsel had an opportunity to put on testimony and evidence at the MCPB hearing. In lieu of doing so, Longmire simply "stipulate[d] to the charges as was read" and made a closing statement. (Id. at 81-82.) During that closing statement, Longmire's counsel re-emphasized plaintiff's position that the December 16 hearing was procedurally deficient under MCPB rules. (Id. at 88.) The hearing then concluded and the MCPB took the matter under submission.

On March 20, 2014, the MCPB issued a five-page Order (doc. 13-7) that recited the charges and specifications against Longmire, summarized the testimony and exhibits presented at the March 6 hearing, and affirmed the demotion decision. In so doing, the March 20 Order reflected the Personnel Board's unanimous conclusions that (i) "the Appointing Authority has met the burden of proof cast upon it;" (ii) Longmire had admitted to the conduct charged, and the MPCB was "satisfied that CARLA LONGMIRE was guilty of all the charges;" and (iii) the MCPB had considered de novo what discipline should be imposed against Longmire for her misconduct, and found that "demotion is the appropriate sanction." (Doc. 13-7.)

D. The State-Court Appeals.

As was her right, Longmire appealed the Personnel Board's decision to the Circuit Court of Mobile County, Alabama. With the benefit of multiple hearings and summary judgment briefing, Circuit Judge Brooks entered a nine-page Order (doc. 13-8) on August 7, 2015, affirming the MCPB's decision to demote Longmire to the rank of lieutenant and entering final judgment in the City's favor. The Circuit Court Order recognized Longmire's argument "that the Personnel Board violated its own rules and regulations as it relates to due process, timeliness and notice and failure to demand the presence of the Appointing Authority at the appeal hearing." (Doc. 13-8, at 7.) In finding no merit to those contentions, the Circuit Court Order observed that Longmire's counsel had previously litigated those same procedural objections in a case called Angela Wright v. City of Mobile, and that the Alabama Court of Civil Appeals had rejected all such arguments. (Id. at 7-8.) The Circuit Court Order articulated the following findings:

(Id. at 8.)

Longmire appealed the Mobile County Circuit Court's decision all the way through the Alabama appellate courts. On September 16, 2016, the Alabama Court of Civil Appeals issued a Certificate of Judgment confirming that (i) that court had affirmed the Circuit Court's judgment on April 22, 2016; and (ii) the Alabama Supreme Court had denied Longmire's petition for writ of certiorari on September 16, 2016. (Doc. 34-2.)8

E. The "Due Process" Lawsuit.

On December 16, 2015, after the Mobile County Circuit Court had entered judgment against Longmire and while her administrative appeals were winding through the Alabama appellate courts, Longmire filed the present collateral lawsuit in Mobile County Circuit Court against the City Defendants, the MCPB and Dees.9 As noted, Longmire seeks relief in this action for alleged deprivations of her procedural due process rights under both the U.S. Constitution and the Alabama Constitution.

An obvious threshold inquiry is why Longmire chose to assert her constitutional due process claims in a separate lawsuit, rather than simply folding those causes of action into her preexisting litigation in the Alabama courts appealing from the demotion decision. The answer is that Alabama courts have limited jurisdiction on administrative appeals of personnel matters, and that such jurisdiction is not sufficiently broad to encompass constitutional due process claims. See, e.g., Wright v. City of Mobile, 170 So.3d 656, 661 (Ala.Civ.App. 2014) ("On appeal from a board's decision on a personnel matter, a trial court likewise lacks jurisdiction to decide a constitutional issue because of its limited standard of review. . . . A constitutional issue may be raised properly only in a separate and distinct collateral suit.") (citations and internal marks omitted).10 The point is simple: This collateral action is Longmire's lone available vehicle for raising constitutional challenges concerning the manner in which her pre-disciplinary and post-disciplinary hearings were noticed, conducted and decided by defendants. It was, therefore, proper for Longmire to raise her § 1983 due process claims in a separate lawsuit from her administrative appeals.

That said, the law is clear that the Personnel Board was authorized to consider and decide issues concerning compliance vel non with its own rules and regulations; thus, Longmire has been able to litigate — and has in fact litigated — her procedural objections to what she says are serious violations of the MCPB rules in her state administrative appeals, and the Alabama courts have fully adjudicated her claims that the City and the MCPB failed to adhere to MCPB rules in the pre-disciplinary and post-disciplinary hearings. The only issues that the Alabama courts have not addressed in her administrative appeals — because they were not empowered to decide such matters for the reasons stated supra — are Longmire's constitutional claims relating to alleged deprivations of procedural due process. Those constitutional issues are the raison d'etre of this collateral litigation and represent the sole reason we are here today.

At the close of discovery, all parties filed overlapping motions for partial or complete summary judgment. In particular, the City Defendants move for summary judgment on the grounds that, inter alia, the record does not establish any constitutional deprivations with regard to the pre-disciplinary hearing, there is no evidence of a municipal custom or policy resulting in any such deprivation, principles of collateral estoppel bar Longmire from relitigating certain issues here, and the failure to train claims are unsupported by the record. (See doc. 36.) The MCPB moves for summary judgment on the grounds that, inter alia, the City's pre-disciplinary hearing comported with procedural due process, the MCPB's post-disciplinary hearing gave Longmire an opportunity (of which she chose not to avail herself) to correct any erroneous deprivation of her property rights at the pre-disciplinary hearing, and Alabama law provides an adequate remedy for any procedural due process violations that may have occurred. (See doc. 40.) Defendant Dees moves for summary judgment on much the same grounds. (See doc. 38.)11 And Longmire has also filed a Rule 56 Motion wherein she seeks partial summary judgment against defendants "for their failure to provide her all due process rights as required by the Rules of the [MCPB] relating to her right to confront witnesses against her." (Doc. 44, at 5.) All of these motions have been the subject of extensive briefing.

III. Summary Judgment Standard.

Summary judgment should be granted only "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Rule 56(a), Fed.R.Civ.P. The party seeking summary judgment bears "the initial burden to show the district court, by reference to materials on file, that there are no genuine issues of material fact that should be decided at trial." Clark v. Coats & Clark, Inc., 929 F.2d 604, 608 (11th Cir. 1991). Once the moving party has satisfied its responsibility, the burden shifts to the non-movant to show the existence of a genuine issue of material fact. Id. "If the nonmoving party fails to make `a sufficient showing on an essential element of her case with respect to which she has the burden of proof,' the moving party is entitled to summary judgment." Id. (quoting Celotex Corp. v. Catrett, 477 U.S. 317 (1986)) (footnote omitted). "In reviewing whether the nonmoving party has met its burden, the court must stop short of weighing the evidence and making credibility determinations of the truth of the matter. Instead, the evidence of the non-movant is to be believed, and all justifiable inferences are to be drawn in his favor." Tipton v. Bergrohr GMBH-Siegen, 965 F.2d 994, 999 (11th Cir. 1992) (internal citations and quotations omitted). "Summary judgment is justified only for those cases devoid of any need for factual determinations." Offshore Aviation v. Transcon Lines, Inc., 831 F.2d 1013, 1016 (11th Cir. 1987) (citation omitted).

IV. Analysis.

A. Plaintiff's Efforts to Equate MCPB Rules with Constitutional Requirements.

From a plain reading of the Complaint and the summary judgment submissions, it is clear that Longmire's claims are grounded in what she characterizes as defendants' noncompliance with Mobile County Personnel Board Rules.12 Indeed, the Complaint alleges that "[b]y demoting Plaintiff without following mandatory and non-discretionary Mobile County Merit System due process procedures, Defendants deprived the Plaintiff of her property rights interest in her job . . . without due process of law. As such, the `demotion' violated the due process clause of the Fourteenth Amendment." (Complaint, ¶ 13.) The Complaint goes on to allege that defendants' violations of MCPB Rule 14.3(a) amount to "a `demotion' of Plaintiff Longmire without the benefit of due process." (Id., ¶ 14.) Plaintiff expressly asserts in her Complaint that the procedural protections created by Rule 14.3(a) "cannot be abridged without due process of law." (Id., ¶ 24.)

Longmire repeatedly articulated this theory (i.e., that violations of MCPB rules are tantamount to Fourteenth Amendment due process deprivations) in her summary judgment briefs. In her own Rule 56 Motion, Longmire framed her constitutional claim in the following terms: "[T]his is not a challenge by Plaintiff that the process afforded by state law is insufficient under the Constitution, but that the City of Mobile has failed to follow the procedure that is provided by law, and thereby, has denied Plaintiff the process that is due her under the law." (Doc. 44, at 4-5.) She further reasoned that "once the due process rights were conferred by . . . MCPB Rules possessing force and effect of law, it may not constitutionally authorize the deprivation of such interest without appropriate safeguards." (Doc. 55, at 4.)13

There are two distinct legal infirmities with Longmire's attempt to structure her Fourteenth Amendment due process claims as being grounded in violations of Mobile County Personnel Board rules. First, it is incorrect as a matter of law to argue (as plaintiff does) that a federal constitutional violation occurs whenever the City of Mobile or the Mobile County Personnel Board fails to adhere strictly to MCPB rules and regulations. As a matter of well-settled law, the process that is due before a property interest may be deprived is defined by reference to federal constitutional jurisprudence, not state or local procedural rules. See, e.g., Maddox v. Stephens, 727 F.3d 1109, 1124 n.5 (11th Cir. 2013) ("Of course, the law is well established that the mere failure to follow state procedures does not necessarily rise to the level of a violation of federal procedural due process rights.").14 The Eleventh Circuit has taken pains to "emphasize that the violation of a state statute outlining procedure does not necessarily equate to a due process violation under the federal constitution. If otherwise, federal courts would have the task of insuring strict compliance with state procedural regulations and statutes." Harris v. Birmingham Bd. of Educ., 817 F.2d 1525, 1528 (11th Cir. 1987). Simply put, "the procedural component of the Due Process Clause does not require the States to comply with state-created procedural rules." Gissendaner v. Commissioner, Georgia Dep't of Corrections, 794 F.3d 1327, 1330 (11th Cir. 2015). For that reason, the Court rejects Longmire's efforts to equate every alleged violation of MCPB rules with a deprivation of her procedural due process rights under the U.S. Constitution.15

Second, to the extent that Longmire's constitutional claims are predicated on arguments that the City Defendants, the MCPB and Dees did not adhere to Personnel Board rules and regulations, this lawsuit faces an insuperable Rooker-Feldman problem. As noted supra, after the Personnel Board affirmed her demotion, Longmire appealed that determination to the Mobile County Circuit Court, at which time she was free to raise (and did raise) arguments that the City and the MCPB had failed to comply with procedural requirements prescribed by the Board's rules and regulations. On August 7, 2015, the Mobile County Circuit Court entered an order affirming Longmire's demotion and making express findings that "the Personnel Board's action was not `unlawful' or `unreasonable' within the meaning of Local Act 470," and that "all rules and timely notices were adhered to." (Doc. 13-8, at 8.) In December 2015, four months later, Longmire brought this collateral action wherein she asks this Court to find due process violations based on an underlying determination that the Personnel Board's actions were unlawful and that all MCPB rule and notices were not adhered to. In other words, Longmire is effectively asking this Court to review and re-visit a final state court decision made adversely to her as to whether procedures prescribed by the MCPB rules were followed in her pre-disciplinary and post-disciplinary hearings.

"The Rooker-Feldman doctrine makes clear that federal district courts cannot review state court final judgments because that task is reserved for state appellate courts or, as a last resort, the United States Supreme Court." Casale v. Tillman, 558 F.3d 1258, 1260 (11th Cir. 2009). "The doctrine applies both to federal claims raised in the state court and to those `inextricably intertwined' with the state court's judgment. . . . A claim is inextricably intertwined if it . . . succeeds only to the extent that the state court wrongly decided the issues." Id. (citations and internal quotation marks omitted). Although Rooker-Feldman is a narrow doctrine, it unquestionably applies "with full force to cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments." Id. at 1261 (citation and internal quotation marks omitted).

That is precisely the situation here, at least insofar as Longmire's due process claims are rooted in arguments that defendants failed to comply with the MCPB rules and regulations. After all, the state court rejected Longmire's contentions that MCPB rules were violated in connection with either her pre-disciplinary hearing conducted by the City or her post-disciplinary hearing conducted by the MCPB, and expressly found that "all rules and timely notices were adhered to." (Doc. 13-8, at 8.) After that state court judgment was entered, Longmire filed the instant collateral lawsuit. Although she raises federal constitutional claims here (which she did not and could not present in the underlying state-court proceedings), the two sets of claims are inextricably intertwined because Longmire's position is that defendants violated her due process rights by not following MCPB rules and regulations; in other words, given her theory of liability, Longmire's due process claims asserted in this action can succeed only if this Court finds that the state court wrongly decided the issues of whether defendants complied with MCPB rules. Thus, this is a textbook example of a lawsuit barred by the Rooker-Feldman doctrine because, to the extent her due process claims hinge on violations of state or local procedural rules and regulations, Longmire is asking this Court to reexamine and reject prior state-court findings (embodied in a final judgment) that the City and Personnel Board did not violate those rules and regulations. See, e.g., Vasquez v. YII Shipping Co., 692 F.3d 1192, 1195-96 (11th Cir. 2012) (confirming that Rooker-Feldman "doctrine holds that federal courts below the Supreme Court must not become a court of appeals for state court decisions" and that such doctrine applies to cases "brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments") (citation, emphasis and internal quotations omitted).

The only way this Court could rule in Longmire's favor on her claim that defendants violated her constitutional rights by failing to comply with MCPB rules would be by effectively reviewing and overturning the state courts' prior final judgment that no such rule violations occurred. Therefore, Rooker-Feldman principles preclude this Court from addressing the merits of Longmire's constitutional claims insofar as those claims proceed from a theory that MCPB rules were violated in connection with her pre-disciplinary and post-disciplinary hearings. This Court does not and cannot sit as an additional layer of appellate review for Alabama state-court determinations that no such violations of MCPB rules and regulations occurred in Longmire's disciplinary hearings.

The foregoing considerations at least arguably dispose of Longmire's constitutional claims in their entirety. Nonetheless, in an abundance of caution, the Court will review the record to ascertain whether the process given to Longmire in connection with the pre-disciplinary and post-disciplinary hearings comported with federal constitutional minimum thresholds, separate and apart from Longmire's now-rejected arguments that non-compliance with state and local procedural rules equates to a Fourteenth Amendment violation.

B. Pre-Deprivation Due Process Requirements.

As a matter of federal constitutional law, it is well-settled that procedural due process "requires `some kind of a hearing' prior to the discharge of an employee who has a constitutionally protected property interest in his employment." Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532, 542, 105 S.Ct. 1487, 84 L.Ed.2d 494 (1985) (citations omitted). The same is true as to a demotion. That said, the Supreme Court has emphasized that a pre-disciplinary hearing, "though necessary, need not be elaborate." Id. at 545. All that is needed to satisfy due process at the pre-disciplinary stage "are notice and an opportunity to respond. . . . The tenured public employee is entitled to oral or written notice of the charges against him, an explanation of the employer's evidence, and an opportunity to present his side of the story. . . . To require more than this prior to termination would intrude to an unwarranted extent on the government's interest in quickly removing an unsatisfactory employee." Id. at 546.16 Such a pre-disciplinary hearing "is not a mini-trial," but simply functions as "an initial check against mistaken decisions — essentially, a determination of whether there are reasonable grounds to believe that the charges against the employee are true and support the proposed action." McKinney v. Pate, 20 F.3d 1550, 1561 (11th Cir. 1994). The Eleventh Circuit's decision in McKinney v. Pate is instructive. There, the court found that the plaintiff "received written notice of the charges against him; at the Board hearing, he also heard an explanation of the Board's evidence; finally, with the assistance of counsel, he had the opportunity to present his side of the story through witnesses, evidence, and argument." McKinney, 20 F.3d at 1561. On those facts, the Eleventh Circuit concluded that the plaintiff's pre-termination hearing included "all the process due under Loudermill." Id. at 1562.

The same is true here. The City Defendants gave Longmire written notice of the charges against her, including detailed factual specifications, six days in advance of the pre-disciplinary hearing. That written notice alerted Longmire that (i) the contemplated disciplinary action was demotion, suspension of up to 30 days, or dismissal; (ii) she would be given an opportunity to enter a plea at the hearing; (iii) she would be afforded "a chance to respond verbally to the alleged charges" at the hearing if she wished; (iv) she was entitled to have legal counsel and/or a representative present at the hearing; (v) she was entitled to submit a list of witnesses to present relevant testimony on her behalf; and (vi) if she were disciplined, she had a right to appeal under MCPB rules. At the pre-disciplinary hearing itself, Longmire was told what the charges were, given an opportunity to enter a plea, and invited to present testimony and explain the charged conduct. These circumstances, taken in the aggregate, comport with the minimum pre-disciplinary due process guarantees as established by Loudermill and its progeny.

In arguing otherwise, Longmire balks that the December 10 Notice should have said something more or different than it did (i.e., it should have specified that the hearing was proceeding under MCPB Rule 14.3(a) rather than Mobile Police Department rules, that the City intended to call witnesses to testify outside of Longmire's presence, and that Longmire had a right to provide a written statement rather than testifying orally) and that it violated her due process rights for the Trial Board to examine adverse witnesses in her absence. With regard to notice, constitutional due process principles require nowhere near the level of detail that Longmire insists should have been furnished to her; to the contrary, notice of a pre-disciplinary hearing need not even be in writing to comport with constitutional guarantees. See, e.g., Harrison v. Willie, 132 F.3d 679, 684 (11th Cir. 1998) ("Notice was sufficient if it notified Plaintiff of the charges and was timely, whether oral or written."); Burton v. Alabama Dep't of Agriculture & Industries, 587 F.Supp.2d 1220 (M.D. Ala. 2008) (no due process violation as to notice of pre-disciplinary hearing, even though employee received notice late in the afternoon on the day prior to the hearing, where "[n]othing indicates that the short notice prevented Burton from participating in this hearing to the extent called for by the nature of the proceeding").

As for Longmire's objections that she was not allowed to confront and cross-examine the City's witnesses against her, she had no such constitutional right at the pre-disciplinary stage. See, e.g., Brock v. Roadway Exp., Inc., 481 U.S. 252, 266, 107 S.Ct. 1740, 95 L.Ed.2d 239 (1987) (in employee reinstatement context, "the employer's interest is adequately protected without the right of confrontation and cross-examination, again so long as the employer is otherwise provided an opportunity to respond at a meaningful time and in a meaningful manner") (citation and internal quotation marks omitted).17 Again, the rule is simple: "Before termination, a full evidentiary hearing is not required. . . . Plaintiff need only be given an opportunity to present his side of the story." Harrison, 132 F.3d at 684. Longmire received that opportunity at the pre-disciplinary hearing. She was not entitled under the Fourteenth Amendment to a pre-termination mini-trial with full confrontation and cross-examination rights for any adverse witnesses. Longmire has presented no constitutional authority to the contrary; therefore, the Court readily finds that the City Defendants' December 16 hearing for Longmire comported with minimum constitutional requirements for procedural due process at the pre-deprivation stage.18

C. Post-Deprivation Due Process Requirements.

Longmire has also challenged whether she received due process in connection with her post-deprivation hearing before the MCPB. She complains that the MCPB displayed bias by summarily denying motions to dismiss predicated on alleged procedural defects at the pre-disciplinary hearing. She objects that defendants failed to issue subpoenas for witnesses she requested at the post-deprivation hearing, namely, Mayor Stimpson (to elicit testimony about what he knew or did not know about the case) and Dees (to examine him as to his investigation of the pre-disciplinary hearing's compliance with MCPB rules). And she complains that the MCPB denied her request for continuance to seek a writ of mandamus as to the alleged procedural violations in the pre-disciplinary hearing.

On this record, the Court finds no genuine factual disputes as to whether Longmire's post-disciplinary hearing before the MCPB was conducted in a manner that comports with Fourteenth Amendment due process requirements. She received considerable advance notice of the hearing. She was allowed to be represented (and was in fact represented) by counsel of her choosing. She was permitted to cross-examine the City's witnesses and was given an opportunity to present evidence bearing on the merits of the conduct underlying her demotion or explaining why she believed she should not be demoted for having engaged in such conduct.19 Her counsel was allowed to make a closing argument on her behalf. Plaintiff has offered no persuasive argument or authority that Fourteenth Amendment due process principles required more from the MCPB at the post-demotion hearing conducted on March 6, 2014.20

Even if the March 6, 2014 hearing held by the Personnel Board were conducted in a manner that infringed upon Longmire's procedural due process rights, her constitutional claim would nonetheless fail because the State of Alabama provided an adequate mechanism (i.e., administrative review by the state court system) to remedy any such procedural deprivations. Once again, the Eleventh Circuit's decision in McKinney v. Pate illustrates the point. The plaintiff in McKinney was a public employee who alleged that the decision maker in his disciplinary proceedings was biased, such that those proceedings violated procedural due process guarantees. The federal appellate court rejected this argument, based on the key observation that "[a] demonstration that the decisionmaker was biased, however, is not tantamount to a demonstration that there has been a denial of procedural due process." McKinney, 20 F.3d at 1562. After all, "procedural due process violations do not become complete unless and until the state refuses to provide due process." Id. (citation and internal quotation marks omitted). Thus, "even if McKinney suffered a procedural deprivation at the hands of a biased Board at his termination hearing, he has not suffered a violation of his procedural due process rights unless and until the State of Florida refuses to make available a means to remedy the deprivation." Id. at 1563. These principles are firmly entrenched in Circuit jurisprudence.21

Alabama Local Act 470 creates a specific mechanism for remedying any procedural deprivations that may occur at the Personnel Board hearing level. In particular, the Act provides as follows:

(Doc. 13-2, at § XXXIV (emphasis added).) Thus, the State of Alabama has created a mechanism for judicial review, whereby an aggrieved employee who has suffered procedural defects at the administrative level before the Personnel Board may obtain judicial review to correct those procedural errors, remedy the deprivation, and make certain that the administrative proceedings conform to all applicable procedural rules. Where violations occur, Alabama courts are empowered to set aside decisions of the Personnel Board or modify them as appropriate.

In the face of these legal principles and the undisputed fact that the State of Alabama provided a remedial process whereby Longmire could obtain judicial review to correct any procedural deprivations (such as biased decision makers or noncompliance with MCPB rules) that might have occurred at the post-disciplinary hearing, plaintiff has made no showing that this remedial process is inadequate. She has not shown that the state refused to provide any remedial procedures, or that the State's procedures were otherwise unavailable to her or inadequate to remedy the alleged procedural deprivations. Nor can she. After all, Longmire was able to (and did) appeal the MCPB ruling through the Mobile County Circuit Court, up through the Alabama Court of Civil Appeals, and even sought a writ of certiorari from the Alabama Supreme Court, then made a second trip through the Alabama courts on Rule 60(b) review, raising a plethora of alleged procedural defects as grounds for relief along the way.22

It is no effective response to argue — as Longmire does — that (in contrast to Florida procedures at issue in McKinney) the Alabama remedial process is inadequate because Local Act 470 does not allow reviewing courts to decide questions of constitutional law, such that she has never been able to present her Fourteenth Amendment due process claims as part of the state remedial process. (See doc. 51, at 23-24.) The Alabama judicial review procedures have been deemed adequate by the Eleventh Circuit, even in the face of arguments quite similar to Longmire's. See, e.g., Bell v. City of Demopolis, Ala., 86 F.3d 191, 192 (11th Cir. 1996) ("Alabama courts, however, like Florida courts, review employment termination proceedings both to determine whether they are supported by substantial evidence and to see that the proceedings comport with procedural due process. . . . [I]n this case, the state offers an adequate remedy in the form of administrative as well as state court review.").23

More fundamentally, recall that Longmire's Fourteenth Amendment due process objections to her post-disciplinary hearing in this litigation deal mostly with allegations that MCPB and Dees violated MCPB rules. (See, e.g., doc. 51, at 1.) Alabama courts unquestionably have authority during the administrative appeal process to adjudicate allegations that the post-disciplinary hearing contravened applicable Personnel Board rules. That Longmire restates and reformulates those claims for non-compliance with MCPB rules in constitutional terms in this action in no way diminishes the effectiveness or adequacy of the state remedial process to provide a remedy for those procedural defects by ruling directly on whether the MCPB rules were violated, whether the decision maker was biased, and so on.24

There is one exception to the foregoing analysis. In her summary judgment briefs, Longmire insists that "the issue whether Rule 14.3(a) complies with due-process guaranties is squarely before this Honorable Court." (Doc. 51, at 25.) This premise is not backed by citations to the record, and the Court has reviewed the pleadings in vain for any indication that Longmire has ever asserted a claim in this action that MCPB Rule 14.3(a) violates the Fourteenth Amendment by allowing a municipal official to decide an employee's discipline without attending the disciplinary hearing. Such a claim simply does not appear in the Complaint and has not been joined in this litigation.25 Of course, a litigant cannot amend her complaint through summary judgment briefing. See, e.g., GeorgiaCarry.Org, Inc. v. Georgia, 687 F.3d 1244, 1258 n.27 (11th Cir. 2012) ("It is well-settled in this circuit that a plaintiff may not amend the complaint through argument at the summary judgment phase of proceedings."); Kirksey v. Schindler Elevator Corp., 2016 WL 6462176, *4 (S.D. Ala. Oct. 28, 2016) (similar). Therefore, the Court rejects plaintiff's argument that she has asserted a viable § 1983 claim in this action, and specifically finds that Longmire has not brought a claim that Rule 14.3(a) violates the Due Process Clause insofar as it allows the disciplinary decision maker to be absent from the hearing room.26

In short, plaintiff's Fourteenth Amendment due process claims relating to her post-disciplinary hearing fail as a matter of law because there is no evidence that the March 6 hearing fell short of the Fourteenth Amendment's minimum procedural requirements. Even if such evidence did exist, dismissal of the § 1983 claim would still be warranted because the State of Alabama has made available an adequate remedy to cure the procedural deprivations about which she complains.

D. Other Claims/Theories of Liability.

The foregoing discussion is dispositive of Longmire's § 1983 due process claim. There are no genuine issues of material fact, and the Court finds as a matter of law that (i) plaintiff's Fourteenth Amendment claims are not actionable insofar as she is complaining about violations of Mobile County Personnel Board rules and regulations; (ii) the pre-disciplinary hearing satisfied minimum procedural due process requirements prescribed by the U.S. Constitution; and (iii) plaintiff's claims relating to post-disciplinary hearing due process violations are not actionable because that hearing comported with Fourteenth Amendment requirements and, even if it did not, the State of Alabama provided an adequate remedial process. These rulings dispose of most of Longmire's claims asserted in the Complaint; however, the Court will separately address her remaining theories of liability, namely, claims of failure to train against the City Defendants, claims of a policy/custom of constitutional deprivations by the City Defendants, and state-law constitutional claims against all defendants.

First, Longmire has attempted to assert § 1983 failure-to-train claims against all defendants, based on their failure to provide training relating to the MCPB rules and regulations.27 It is well-settled that "under § 1983, a supervisor can be held liable for failing to train his or her employees only where the failure to train amounts to deliberate indifference to the rights of persons with whom the [officers] come into contact." Keith v. DeKalb County, Georgia, 749 F.3d 1034, 1052 (11th Cir. 2014) (citations and internal quotation marks omitted). "But a pattern of similar constitutional violations by untrained employees is ordinarily necessary to demonstrate deliberate indifference for purposes of failure to train." Weiland v. Palm Beach County Sheriff's Office, 792 F.3d 1313, 1328 (11th Cir. 2015) (citation and internal marks omitted). The record lacks any evidence of a pattern of violations, or any other facts that might support a finding of deliberate indifference. More fundamentally, Longmire has identified no authority or legal principle that might confer upon her a constitutional right to receive "necessary personnel training related to the Rules of the Mobile County Personnel Board." (Complaint, ¶ 15.) As discussed supra, due process requires notice, and the notice provided to Longmire in this case was constitutionally adequate. The Fourteenth Amendment does not require that defendants furnish training to Longmire and other employees relating to disciplinary hearing protocols and policies, provided that adequate notice is given (which it was).

Second, to the extent that Longmire is bringing a § 1983 claim against the City of Mobile, well-settled law requires that she identify a municipal policy or custom that caused the injury. See, e.g., Hill v. Cundiff, 797 F.3d 948, 977 (11th Cir. 2015) (in § 1983 action, municipality "may be held liable only if such constitutional torts result from an official government policy, the actions of an official fairly deemed to represent government policy, or a custom or practice so pervasive and well-settled that it assumes the force of law") (citations and internal quotation marks omitted); Johnson v. Dixon, 666 Fed.Appx. 828, 830 (11th Cir. Nov. 29, 2016) ("A plaintiff seeking to hold a municipal actor liable under 42 U.S.C. § 1983 must prove that official municipal policy was responsible for the action that caused his injury."). Plaintiff identifies no evidence of any such municipal policy or custom, but simply speculates that the actions of which she complains must have been taken pursuant to a policy or custom, or else they would have been purely arbitrary and capricious. (See doc. 47, at 21.) Such a conclusory argument is not an acceptable substitute for record evidence, and does not create a genuine issue of material fact. Moreover, the Court has already held that the City of Mobile did not violate Longmire's constitutional rights. In the absence of a constitutional violation, the City can have no § 1983 municipal liability based on its policies and customs, as a matter of law. See, e.g., Penley v. Eslinger, 605 F.3d 843, 855 (11th Cir. 2010) ("Because we hold that Lieutenant Weippert did not deprive Mr. Penley of a constitutional right, it is unnecessary for us to evaluate the constitutionality of Sheriff Eslinger's use of force policy."); Garczynski v. Bradshaw, 573 F.3d 1158, 1171 (11th Cir. 2009) ("Absent a constitutional violation, we need not explore whether PBSO's policies regarding crisis intervention training violated Garczynski's constitutional rights."). For all of these reasons, Longmire's efforts to establish § 1983 municipal liability against the City based on a custom or policy of procedural due process violations fail as a matter of law.

Third, aside from her § 1983 procedural due process claim, Longmire's Complaint asserts a state-law due process claim as Count Two. This claim proceeds on the same grounds and theories as plaintiff's federal due process claim. (See Complaint, ¶¶ 26-30.) Count Two adds nothing of substance to Longmire's claims and is due to be dismissed for precisely the same reasons that her federal due process claims are not viable. The Alabama Supreme Court has explained that "[t]his Court has consistently interpreted the due process guaranteed under the Alabama Constitution to be coextensive with the due process guaranteed under the United States Constitution." Vista Land and Equipment, LLC v. Computer Programs & Systems, Inc., 953 So.2d 1170, 1174 (Ala. 2006); City of Orange Beach v. Duggan, 788 So.2d 146, 150-53 (Ala. 2000) (looking to Loudermill and other federal authorities interpreting Due Process Clause of U.S. Constitution to evaluate merits of procedural due process claim asserted under Alabama Constitution).28 In response to these arguments and authorities, plaintiff does not assert (much less cite authority to support the proposition) that the Alabama Constitution's procedural due process protections afforded to her are somehow greater or different than those provided under the Fourteenth Amendment. Thus, the summary judgment analysis is identical for Count One and Count Two. Plaintiff having failed to present a viable federal constitutional claim for deprivation of her procedural due process rights, her state-law constitutional due process claim is likewise properly dismissed for the same reasons.

V. Conclusion.

For all of the foregoing reasons, it is ordered as follows: