The following excerpt is from Schwerdtfeger v. Paramo, Case No.: 19-cv-02255 JLS (JLB) (S.D. Cal. 2021):
8. But see Brown v. Bargery, 207 F.3d 863, 867-68 (6th Cir. 2000) (finding sufficient to state an Eighth Amendment claim an inmate's allegations that the bunks in one of the prison's housing units were "improperly installed upside down, which would pose an unreasonable risk of future injury by causing inmates to fall from their bunks while asleep and by subjecting inmates to the hazards of rolling into sharp protruding mounting bolt studs").
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