What is the test for a prison official to be held liable for failing to protect an inmate from physical abuse?

MultiRegion, United States of America

The following excerpt is from Quinn v. Singh, Case No. 11-CV-1085-DMS (JMA) (S.D. Cal. 2012):

"[T]he treatment a prisoner receives in prison and the conditions under which he is confined are subject to scrutiny under the Eighth Amendment." Farmer v. Brennan, 511 U.S. 825, 832 (1994) (citation omitted). "Prison officials have a duty to take

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reasonable steps to protect inmates from physical abuse." Hoptowit v. Ray, 682 F.2d 1237, 1250 (9th Cir. 1982). "It is not, however, every injury suffered by one prisoner at the hands of another that translates into constitutional liability for prison officials responsible for the victim's safety." Farmer, 511 U.S. at 834. A prison official violates the Eighth Amendment only when two requirements are met, one of which is objective and the other of which is subjective. Id.

"Under the objective requirement, the prison official's acts or omissions must deprive an inmate of 'the minimal civilized measure of life's necessities.'" Allen v. Sakai, 48 F.3d 1082, 1087 (9th Cir. 1994) (citation omitted). A prisoner meets the objective requirement by alleging the deprivation of what courts have defined as a basic human need. Id. at 1088. The subjective requirement requires a prison official to have a "sufficiently culpable state of mind." Farmer, 511 U.S. at 834. In prison conditions cases, that state of mind is "deliberate indifference" to inmate health or safety. Id. "Deliberate indifference" exists when a prison official "knows of and disregards an excessive risk to inmate health or safety; the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference." Id. at 837.

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