The following excerpt is from Schraeger v. City of San Francisco, 8 F.3d 29 (9th Cir. 1993):
Due process only protects against the deprivation of liberty and property interests within the scope of the Fourteenth Amendment. Board of Regents v. Roth, 408 U.S. 564, 569 (1972). Property interests, however, are not created by the Constitution; their source is rules and understandings stemming from an independent source, such as state law. Id. at 577. To have a property interest, a person must have more than an abstract need or a unilateral expectation; protection by the Fourteenth Amendment requires that a person have a legitimate claim of entitlement. Id.
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