The following excerpt is from Valdez v. Farmon, 766 F. Supp. 1529 (E.D. Cal. 1991):
7 This analysis does not entirely preclude a Fourteenth Amendment claim in the prison context. When there is an actual injury to a prison inmate, an injury which is not encompassed by a specific constitutional amendment, the Fourteenth Amendment will provide recovery. See, Washington v. Harper, 494 U.S. 210, 110 S.Ct. 1028, 108 L.Ed.2d 178 (1990) (prisoner has a liberty interest in the non-arbitrary administration of antipsychotic medication).
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