Case Citator › Miltier v. Beorn

Miltier v. Beorn

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Fourth Circuit
Citation
896 F.2d 848
Decided
Confirmed treatments
1
Flagged citations read
267 of 267
Citing cases (total)
715
Treatment dates
1994
Overruled in part
A reviewed court has overruled part of this case’s holding. Overruled in part: all 267 flagged citations have been read, and the confirmed treatment is listed below. Farmer v. Brennan's subjective-knowledge holding displaced Miltier's constructive-knowledge language, and the Fourth Circuit has since carried the parenthetical "overruled in part on other grounds by Farmer" (e.g., Scinto v. Stansberry, 841 F.3d 219, 225 (4th Cir. 2016)); district courts have applied that recognition squarely (Brown v. Mitchell, E.D.
More on how this was screened

Va. 2004). Miltier's other holdings, including the inference from failure to respond to known medical needs, remain in use. The other opinions positively applied those unaffected holdings, copied history parentheticals reporting Farmer's act, or did not mention Miltier.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

715 later cases cite Miltier v. Beorn; 267 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Miltier v. Beorn?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court adopted a purely subjective test for deliberate indifference, displacing Miltier's language allowing liability where a risk "would [have been] apparent to a reasonable person"; the Fourth Circuit has since described Miltier as overruled in part on other grounds by Farmer.

    Farmer v. Brennan · Supreme Court of the United States · filed

    We reject petitioner’s invitation to adopt an objective test for deliberate indifference. We hold instead that a prison official cannot be found liable under the Eighth Amendment for denying an inmate humane conditions of confinement unless the 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.
    Read the full opinion on CourtListener →

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