Farmer v. Brennan, 511 U.S. 825 (1994), was a case in which the Supreme Court of the United States ruled that a prison official's "deliberate indifference" to a substantial risk of serious harm to an inmate violates the cruel and unusual punishment clause of the Eighth Amendment.

[3] In 1989, Farmer was transferred to the general male population at US Penitentiary Terre Haute, Indiana, a higher security facility that housed "more troublesome prisoners.

[11] The federal government argued that the Court should adopt a test more similar to criminal recklessness, which would require that a plaintiff show that the prison official had actual knowledge of the substantial risk of serious harm.

[14] The U.S. Supreme Court ruled in a 9–0 decision that "deliberate indifference" to a substantial risk of harm to an inmate can render a prison official liable under the Eighth Amendment.

The Court explained that the Eighth Amendment requires prison officials to provide humane conditions of confinement, which includes provision of "adequate food, clothing, shelter, and medical care," and taking "reasonable measures" to ensure inmate safety.

Under the deliberate indifference standard, a prison official must actually know of and disregard an excessive risk to inmate health and safety.

In view of this obvious fact, there is no reason to believe that, in adopting the Eighth Amendment, the Framers intended to prohibit cruel and unusual punishments only when they were inflicted intentionally.

[18] Justice Thomas concurred in the judgment only, explaining that conditions of confinement should not violate the Eighth Amendment unless they are imposed as part of a sentence.

By carefully explaining how to argue constitutional violations behind bars, defining complex legal terms like “subjective recklessness” and mapping out a successful claim, Justice Souter's majority opinion serves as a roadmap for Eighth Amendment prison condition litigation.

[1] Nonetheless, the "actual knowledge" focus of the standard adopted by the Court in Brennan sets a high bar for plaintiffs that can often prove difficult to surmount.

[29] Nine years later, Congress passed the Prison Rape Elimination Act of 2003 and both the House and Senate referenced Farmer in floor debates regarding the bill.

[32] In 2012, the Department of Justice announced regulations implementing the PREA, including specific protections for transgender people that referred to Farmer expressly.