The following excerpt is from Dietle v. Miranda, No. 2:14-cv-01728 WBS AC P (E.D. Cal. 2015):
Insofar as plaintiff cites a violation of his rights under the Fourteenth Amendment based on medical care, his claims are properly analyzed under the Eighth Amendment. 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 (1998) (quotation marks and citation omitted).
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