The following excerpt is from Parretti v. U.S., 122 F.3d 758 (9th Cir. 1997):
We find support for our holding in the cases that apply the "special circumstances" doctrine. Those cases recognize that individual interests that are not as weighty as an individual's "core" liberty interest in being free from bodily restraint, see Foucha v. Louisiana, 504 U.S. 71, 80, 112 S.Ct. 1780, 1785, 118 L.Ed.2d 437 (1992) ("Freedom from
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