In Bd. of Pardons v. Allen, 482 U.S. 369, 107 S.Ct. 2415, 96 L.Ed.2d 303 (1987), the Supreme Court noted one could use the term "discretion" in two distinct ways.10 "In one sense of the word, an official has discretion when he or she `is simply not bound by standards set by the authority in question.'" Allen, 482 U.S. at 375, 107 S.Ct. 2415 (citing R. DWORKIN, TAKING RIGHTS SERIOUSLY 32 (1977)). In the alternative, "the term discretion may instead signify that `an official must use judgment in applying the standards set him or her by authority.'" Id. (citing DWORKIN, supra at 31, 32). See also Watson v. City of Kansas City, 857 F.2d 690, 695 (10th Cir.1988) (the determination of probable cause "represents a judgment call on the part of the officer or officers at the scene taking into account the particular circumstances. Although there are clearly guidelines, much depends upon the individual officers' assessment."). In Allen, the Supreme Court concluded parole guidelines created a liberty interest in parole where the guidelines mandated release upon the parole board's finding of certain factors. Allen, 482 U.S. at 381, 107 S.Ct. 2415.