What is the test for a claim that retention in ad seg violated the Eighth Amendment rights of a mentally ill individual?

To succeed on a claim that his retention in ad seg violated his Eighth Amendment rights based on his mental illness, plaintiff must demonstrate some harm to his mental illness. See Madrid v. Gomez, 889 F.Supp. 1146, 1264 (N.D. Cal. 1995.) For example, plaintiff could demonstrate that his mental illness decompensated while he was housed in ad seg. In the instant case, plaintiff has not demonstrated that his incarceration in ad seg caused any harm to his mental illness. For this reason, defendants should be granted summary judgment as to this claim.⁷

Page 28

B. Conditions of Ad Seg