In Watters v. Bd. of Sch. Dir. of the City of Scranton, the 3rd circuit assumed for argument’s sake that Section 1983 provides for a private right of action for a purported violation of the Contracts Clause. The Court then moved on to determine whether a 2017 amendment to Pennsylvania’s Public School Code violated the tenure rights of three suspended teachers. The 3rd Circuit held that the teachers failed to state a claim on which relief could be granted, because the School District had tried other cost-cutting measures before suspending the teachers, but the savings were insufficient, and the School District complied with state laws in suspending the teachers.