was the private property of the client. 524 U.S. at 173, 118 S.Ct. 1925. This Court agrees that, as a general proposition, interest does indeed follow principal. See id. at 165, 118 S.Ct. 1925 (“interest shall follow the principal, as the shadow the body”) (quoting Beckford v. Tobin, 27 Eng. Rep. 1049, 1051 (Ch. 1749) (internal quotations omitted)). Thus, in the case of the ordinary citizen, the interest earned on wages placed in a bank account is undoubtedly the property of the citizen who performed the labor. But prisoners are not ordinary citizens. As the Magistrate Judge noted, there is a split in the circuits as to whether the interest generated from the investment of prisoner wages constitutes private property for purposes of the Takings Clause. Compare Givens, 381 F.3d at 1070 (<HOLDING>), and Washlefske, 234 F.3d at 186 (same), with
holding that plaintiffs may have a property interest in real property holding inmates possess a constitutionally cognizable property interest in the interest earned on money held in their prison accounts holding that because prisoner did not have private property interest in his prison accounts there could be no unconstitutional taking holding that pay on death accounts were not part of the bankruptcy estate under  541 because under kansas law debtor had no property interest in the accounts until the death of the owner holding a prisoner has no constitutional right to a job in prison