Elliott v. Martinez, -- F.3d --, 2012 WL 1153488 (4/9/12) - The New Mexico statutory requirement that an individual be informed that he or she is a target of a grand jury investigation constitutes a procedural limitation which does not create a substantive liberty interest protected by the Fourteenth Amendment Due Process Clause. Because the plaintiffs did not have a constitutional right to compliance with the grand jury procedures, they were not entitled to relief under § 1983.