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appealsummary judgmentrespondent
appealsummary judgmentrespondent

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Farmer v. Brennan

Facts

The dispute before us stems from a civil suit brought by petitioner, Dee Farmer, alleging that respondents, federal prison officials, violated the Eighth Amendment by their deliberate indifference to petitioner's safety. Petitioner, who is serving a federal sentence for credit card fraud, has been diagnosed by medical personnel of the Bureau of Prisons as a transsexual. The practice of federal prison authorities is to incarcerate preoperative transsexuals with prisoners of like biological sex, and over time authorities housed petitioner in several federal facilities, sometimes in the general male prison population but more often in segregation. On March 9, 1989, petitioner was transferred for disciplinary reasons to the United States Penitentiary in Terre Haute, Indiana, where he was placed in the general population and subsequently assaulted by another inmate.

The dispute before us stems from a civil suit brought by petitioner, Dee Farmer, alleging that respondents, federal prison officials, violated the Eighth Amendment by their deliberate indifference to petitioner's safety. Petitioner, who is serving a federal sentence for credit card fraud, has been diagnosed by medical personnel of the Bureau of Prisons as a transsexual. The practice of federal prison authorities is to incarcerate preoperative transsexuals with prisoners of like biological sex, and over time authorities housed petitioner in several federal facilities, sometimes in the general male prison population but more often in segregation. On March 9, 1989, petitioner was transferred for disciplinary reasons to the United States Penitentiary in Terre Haute, Indiana, where he was placed in the general population and subsequently assaulted by another inmate.

Issue

The main legal issue was whether the prison officials acted with 'deliberate indifference' to the inmate's safety, thereby violating the Eighth Amendment.

The main legal issue was whether the prison officials acted with 'deliberate indifference' to the inmate's safety, thereby violating the Eighth Amendment.

Rule

A prison official's 'deliberate indifference' to a substantial risk of serious harm to an inmate violates the Eighth Amendment. The official must be subjectively aware of the risk and must disregard it.

A prison official's 'deliberate indifference' to a substantial risk of serious harm to an inmate violates the Eighth Amendment. The official must be subjectively aware of the risk and must disregard it.

Analysis

The Court applied the rule by examining whether the prison officials had the requisite subjective knowledge of the risk to Farmer's safety. The Court noted that the summary judgment record did not clearly establish that the officials were entitled to judgment as a matter of law on the issue of subjective knowledge, as there was evidence that they may not have been aware of the specific risks posed to Farmer.

The Court applied the rule by examining whether the prison officials had the requisite subjective knowledge of the risk to Farmer's safety. The Court noted that the summary judgment record did not clearly establish that the officials were entitled to judgment as a matter of law on the issue of subjective knowledge, as there was evidence that they may not have been aware of the specific risks posed to Farmer.

Conclusion

The Supreme Court vacated the judgment of the court of appeals and remanded the case for further proceedings, indicating that the issue of deliberate indifference required further examination.

The Supreme Court vacated the judgment of the court of appeals and remanded the case for further proceedings, indicating that the issue of deliberate indifference required further examination.

Who won?

The prevailing party was the petitioner, Dee Farmer, as the Supreme Court vacated the lower court's decision and remanded the case for further proceedings.

The prevailing party was the petitioner, Dee Farmer, as the Supreme Court vacated the lower court's decision and remanded the case for further proceedings.

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