The following excerpt is from Jackson v. Akkano, 1:13cv00009 DLB PC (E.D. Cal. 2014):
Plaintiff also contends that the allegations giving rise to his Eighth Amendment claim also violate the Due Process Clause of the Fourteenth Amendment. However, the concept of substantive due process is expanded only reluctantly and therefore, if a constitutional claim is covered by a specific constitutional provision, the claim must be analyzed under the standard appropriate to that specific provision, not under the rubric of substantive due process. County of Sacramento v. Lewis, 523 U.S. 833, 843, 118 S.Ct. 1708 (1998) (quotation marks and citation omitted).
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