is “a limited property right in the amounts deposited in [his name] — specifically ... the limited right to access [his] deposits when permitted by statute, regulation, or policy.” Givens, 381 F.3d at 1067 (discussing Washlefske, 234 F.3d at 185-86). 2. Do Prisoners Have Property Rights in Interest Under the “Interest Follows Principal” Rule? Young relies on the common law maxim that “interest follows principal” in claiming a property right in the interest earned on his funds. In Phillips, the Supreme Court held that the interest earned on client funds held in Texas’s Interest on Lawyers Trust Account (“IOLTA”) program was the private property of the client because the interest followed the principal and the princi hneider v. Calif. Dep’t of Corrs., 151 F.3d 1194, 1201 (9th Cir.1998) (<HOLDING>). In Washlefske, the Fourth Circuit found that
holding that prisoners possess constitutionally cognizable property right that implicates takings clause scrutiny in any interest earned from paid labor holding that constitutionally protected property interest in employment does not extend to right to possess and retain particular job or to perform particular services holding that inmates have no constitutionally protected interest in the wages earned while in prison holding that a prisoners loss of privileges for thirty days was not a property right that would constitute a violation of his constitutionally protected liberty interest holding inmates possess a constitutionally cognizable property interest in the interest earned on money held in their prison accounts