The following excerpt is from U.S. v. Phelps, 955 F.2d 1258 (9th Cir. 1992):
A procedural due process analysis proceeds in two steps. First, a liberty or property interest must be involved. Mathews v. Eldridge, 424 U.S. 319, 332, 96 S.Ct. 893, 901, 47 L.Ed.2d 18 (1976). Civil commitment is a significant deprivation of liberty to which procedural due process protections apply. Vitek v. Jones, 445 U.S. 480, 491-92, 100 S.Ct. 1254, 1262-63, 63 L.Ed.2d 552 (1980).
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