Farmer v. Brennan Case Brief

Facts of the Case

“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.”




Maybe. Justice David H. Souter, writing for seven members of the court, vacated the lower court judgment and remanded. The Supreme Court held that prison officials may be liable if they showed “deliberate indifference” to a substantial risk of serious harm when the official was subjectively aware of the risk and disregarded it. The Court remanded the case for further consideration of whether prison officials were aware of the risk to Farmer. Justice Harry A. Blackmun concurred, writing that inhumane prison conditions violate the Eighth Amendment regardless of a prison official’s state of mind. Justice John Paul Stevens also concurred writing that he agreed with Justice Blackmun, but joined in the majority because it followed prior precedent. Justice Clarence Thomas concurred in the judgment arguing that conditions of confinement do not violate the Eighth Amendment unless they are imposed as part of a sentence.

Case Information

Citation: 511 US 825 (1994)
Argued: Jan 12, 1994
Decided: Jun 6, 1994
Granted: Oct 4, 1993
Case Brief: 1994