The following excerpt is from Brown v. County of San Joaquin, 601 F. Supp. 653 (E.D. Cal. 1985):
The Due Process Clause of the Fourteenth Amendment is a source of liberties protected by the requirement of pre-deprivation procedural due process independent of state law. Vitek v. Jones, 445 U.S. 480, 100 S.Ct. 1254, 63 L.Ed.2d 552 (1980). The identification of the precise contours of the liberties protected by the Constitution itself is not easy:
Board of Regents v. Roth, 408 U.S. at 571-72, 92 S.Ct. at 2705-706. It is now well-established, however, that "family rights" are among the liberties protected by the Fourteenth Amendment:
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