Farmer v. Brennan
United States Supreme Court
511 U.S. 825 (1994)
- Written by Angela Patrick, JD
Facts
Dee Farmer (plaintiff), a transgender woman with a feminine appearance, was a federal prisoner. Farmer was transferred to a new prison and incarcerated among the general male prison population. Two weeks later, Farmer was raped and beaten by a fellow inmate. Farmer sued Edward Brennan and other prison officials (defendants) for violating the Eighth Amendment’s prohibition of cruel and unusual punishment. Farmer argued that the officials had acted with deliberate indifference to Farmer’s safety by housing Farmer with men despite knowing that the prison was violent and that Farmer, as a transgender woman, would be especially vulnerable to sexual assault. Farmer alleged that the warden at Farmer’s prior prison had expressed a belief that Farmer would not be safe at the new prison. However, the district court ruled that (1) the officials had acted with deliberate indifference only if they had actual knowledge of the risk to Farmer and (2) the officials lacked actual knowledge of the risk because Farmer never expressly notified them about any safety concerns. The district court rejected Farmer’s requests for additional discovery and granted summary judgment for the officials. The Seventh Circuit affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Souter, J.)
Concurrence (Thomas, J.)
Concurrence (Stevens, J.)
Concurrence (Blackmun, J.)
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