Farmer v. Brennan

511 U.S. 825 (1994)

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Farmer v. Brennan

United States Supreme Court
511 U.S. 825 (1994)

  • Written by Whitney Kamerzel , JD
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Facts

Dee Farmer (plaintiff) was a transsexual, feminine prisoner who was beaten and raped shortly after being transferred to a new federal prison. Farmer sued several prison officials (defendants), including Edward Brennan, alleging the officials knew of Farmer’s transsexual status and the violent environment of the new prison. Farmer argued that the officials were deliberately indifferent to Farmer’s safety in violation of the Eighth Amendment. The district court dismissed the case and held that the officials were not deliberately indifferent, because they did not have actual knowledge of the risk to Farmer. There was evidence the warden at Farmer’s prior prison had expressed that Farmer could not safely function at the new prison. However, the district court found that the officials did not have actual knowledge of the risk to Farmer, because Farmer never expressly told the officials that Farmer was transsexual. The court of appeals affirmed. Because several courts of appeals disagreed whether deliberate indifference required only a subjective awareness of the risk of harm or a subjective and objective awareness of the risk of harm, the Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Souter, J.)

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