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Keywords

appealsummary judgmentrespondent
appealsummary judgmentrespondent

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Wilson; U.S. v.

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. For several years before being convicted, petitioner wore women's clothing, underwent estrogen therapy, and received silicone breast implants. After being transferred to the United States Penitentiary in Terre Haute, Indiana, petitioner was placed in the general population where he was subsequently beaten and raped by another inmate. Petitioner alleged that prison officials failed to protect him despite knowing of the risks he faced as a transsexual 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. For several years before being convicted, petitioner wore women's clothing, underwent estrogen therapy, and received silicone breast implants. After being transferred to the United States Penitentiary in Terre Haute, Indiana, petitioner was placed in the general population where he was subsequently beaten and raped by another inmate. Petitioner alleged that prison officials failed to protect him despite knowing of the risks he faced as a transsexual inmate.

Issue

Whether prison officials acted with 'deliberate indifference' to the safety of an inmate, in violation of the Eighth Amendment.

Whether prison officials acted with 'deliberate indifference' to the safety of an inmate, in violation of the Eighth Amendment.

Rule

A prison official's 'deliberate indifference' to a substantial risk of serious harm to an inmate violates the Eighth Amendment. This requires a showing that the official was subjectively aware of the risk.

A prison official's 'deliberate indifference' to a substantial risk of serious harm to an inmate violates the Eighth Amendment. This requires a showing that the official was subjectively aware of the risk.

Analysis

The Court held that the prison officials could not be found liable under the Eighth Amendment unless they knew of and disregarded an excessive risk to inmate health or safety. The officials needed to be 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. The Court found that the summary judgment record did not clearly establish the prison officials' entitlement to judgment as a matter of law on the issue of subjective knowledge.

The Court held that the prison officials could not be found liable under the Eighth Amendment unless they knew of and disregarded an excessive risk to inmate health or safety. The officials needed to be 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. The Court found that the summary judgment record did not clearly establish the prison officials' entitlement to judgment as a matter of law on the issue of subjective knowledge.

Conclusion

The judgment of the court of appeals was vacated and the case was remanded for further proceedings.

The judgment of the court of appeals was vacated and the case was remanded for further proceedings.

Who won?

The prison officials prevailed in the lower court, as the district court found no deliberate indifference to the inmate's safety.

The prison officials prevailed in the lower court, as the district court found no deliberate indifference to the inmate's safety.

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