What is the test for finding a prison official to have been negligent in protecting an inmate from physical abuse?

MultiRegion, United States of America

The following excerpt is from Roettgen v. Arnold, Civil No. 11-2562 IEG (NLS) (S.D. Cal. 2012):

Prison officials have a duty to take reasonable steps to protect inmates from physical abuse. Farmer v. Brennan, 511 U.S. 825, 833 (1994). To establish a violation of this duty, the prisoner must establish that prison officials were "deliberately indifferent" to serious threats to the inmate's safety. See Farmer, 511 U.S. at 834. To demonstrate a prison official was deliberately indifferent to a serious threat to the inmate's safety, the prisoner must show that "the official [knew] of and disregard[ed]] an excessive risk to inmate. . . 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 [the official] must also draw the inference." Id., at 837. To prove knowledge of the risk, however, the prisoner may rely on circumstantial evidence; in fact, the very obviousness

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of the risk may be sufficient to establish knowledge. See Farmer, 511 at 842.

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