Does Steffen have standing to make a Fourteenth Amendment right to due process claim?

MultiRegion, United States of America

The following excerpt is from Steffen v. Rowland, 972 F.2d 1343 (9th Cir. 1992):

With respect to the Fourteenth Amendment right to due process, we agree that Steffen has not alleged that she was deprived of a liberty or property interest. Most of Steffen's claims relate to her husband's interest in visitation; she has no standing to assert those claims for him. Moreover, Steffen has not alleged that the defendant's actions violated mandatory (as opposed to discretionary) prison regulations and hence that she had a vested liberty or property interest in those privileges. See Kentucky Dept. of Corrections v. Thompson, 490 U.S. 454, 461 (1989). Accordingly, the district court properly dismissed Steffen's due process claim.

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