Law School Case Brief
Farmer v. Brennan - 511 U.S. 825, 114 S. Ct. 1970 (1994)
A prison official violates the Eighth Amendment only when two requirements are met. First, the deprivation alleged must be, objectively, sufficiently serious. For a claim based on a failure to prevent harm, the inmate must show that he is incarcerated under conditions posing a substantial risk of serious harm. The second requirement follows from the principle that only the unnecessary and wanton infliction of pain implicates the Eighth Amendment. To violate the Cruel and Unusual Punishments Clause, a prison official must have a sufficiently culpable state of mind. In prison-conditions cases that state of mind is one of deliberate indifference to inmate health or safety.
Petitioner Dee Farmer, a preoperative transsexual who projects feminine characteristics, was incarcerated with other males in the federal prison system, sometimes in the general prison population but more often in segregation. Farmer claimed to have been beaten and raped by another inmate after being transferred by respondent federal prison officials from a correctional institute to a penitentiary, a higher security facility with more troublesome prisoners, and placed in its general population. Farmer filed suit in federal district court, seeking damages and an injunction barring future confinement in any penitentiary and alleged that respondents acted with "deliberate indifference" to Farmer's safety in violation of the Eighth Amendment because they knew that the penitentiary had a violent environment and a history of inmate assaults and that Farmer would be particularly vulnerable to sexual attack. The district court granted summary judgment to the prison officials, denying Farmer's motion under Federal Rule of Civil Procedure 56(f) to delay its ruling until respondents complied with a discovery request. It concluded that failure to prevent inmate assaults violated the Eighth Amendment only if prison officials were "reckless in a criminal sense," such as having "actual knowledge" of a potential danger. It held that that respondent prison officials lacked such knowledge because Farmer never expressed any safety concerns to them. The court of appeals affirmed.
Were the prison officials liable under the Eight Amendment for acting with "deliberate indifference" to Farmer's safety?
The Supreme Court of the United States declined Farmer's invitation to adopt an objective test for deliberate indifference. Instead, the Court held that the prison officials could not be found liable under the Eighth Amendment for denying Farmer humane conditions of confinement unless the officials knew of and disregarded an excessive risk to inmate health or safety. The prison officials needed to be both aware of facts from which the inference could be drawn that a substantial risk of serious harm existed, and they also had to draw the inference. However, the Court concluded that the summary judgment record did not so clearly establish the prison officials' entitlement to judgment as a matter of law on the issue of subjective knowledge.
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