Farmer v. Brennan

Farmer v. Brennan
Supreme Court of the United States
Argued January 12, 1994 Decided June 6, 1994
Full case name	Dee Farmer, petitioner v. Edward Brennan, Warden, et al.
Citations	511 U.S. 825 (more)
Argument	Oral argument
Holding
A prison official's "deliberate indifference" to a substantial risk of serious harm to an inmate violates the Eighth Amendment.
Court membership
Chief Justice William Rehnquist Associate Justices Harry Blackmun · John P. Stevens Sandra Day O'Connor · Antonin Scalia Anthony Kennedy · David Souter Clarence Thomas · Ruth Bader Ginsburg
Case opinions
Majority	Souter, joined by Rehnquist, Blackmun, Stevens, O'Connor, Scalia, Kennedy, Ginsburg
Concurrence	Blackmun
Concurrence	Stevens
Concurrence	Thomas (in the judgment)
Laws applied
U.S. Const. Amend. VIII

Farmer v. Brennan, 511 U.S. 825 (1994), was a case in which the Supreme Court of the United States ruled that a prison official's "deliberate indifference" to a substantial risk of serious harm to an inmate violates the cruel and unusual punishment clause of the Eighth Amendment. An amicus brief was submitted by Stop Prisoner Rape, which lauded the decision.

Case

Dee Farmer, a trans woman (male-to-female transgender person), was incarcerated with the general male population after being transferred to the US Penitentiary Terre Haute, Indiana. She was repeatedly raped and beaten by the other inmates and acquired HIV as a result. Farmer claimed that the prison administration should have known that she was particularly vulnerable to sexual violence.

The majority opinion of the Court agreed that it was the responsibility of prison officials to prevent prisoners from harming each other, to the point where prison officials who were "deliberately indifferent" were ruled liable under the Eighth Amendment. The court did not make prison officials liable for all violence between inmates.

We [...] hold that a prison official may be held liable under the Eighth Amendment for denying humane conditions of confinement only if he knows that inmates face a substantial risk of serious harm and disregards that risk by failing to take reasonable measures to abate it.

Justice Blackmun's concurring opinion went further, saying that the government was responsible for the conditions inside even if no specific agent of the government had acted in a particularly culpable manner.

Where a legislature refuses to fund a prison adequately, the resulting barbaric conditions should not be immune from constitutional scrutiny simply because no prison official acted culpably. [...] The responsibility for subminimal conditions in any prison inevitably is diffuse, and often borne at least in part, by the legislature. Yet, regardless of what state actor or institution caused the harm and with what intent, the experience of the inmate is the same. A punishment is simply no less cruel or unusual because its harm is unintended. In view of this obvious fact, there is no reason to believe that, in adopting the Eighth Amendment, the Framers intended to prohibit cruel and unusual punishments only when they were inflicted intentionally.

The decision marked the first time the Supreme Court had directly addressed prisoner rape.

See also

• Prison rape in the United States
• List of United States Supreme Court cases, volume 511
• List of United States Supreme Court cases
• Lists of United States Supreme Court cases by volume
• List of United States Supreme Court cases by the Rehnquist Court

External links

• Farmer v. Brennan, 511 U.S. 825 (1994) (full text with links to cited material)