The following excerpt is from Soto v. City of Sacramento, 567 F. Supp. 662 (E.D. Cal. 1983):
While the test for distinguishing "punishment" from legitimate governmental conduct may be "impossible to compress ... into a sentence," Bell v. Wolfish, 441 U.S. at 537, 101 S.Ct. at 1913, one traditional method of determining one from the other has been described as:
[567 F. Supp. 673]
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