Redman v. County of San Diego
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Farmer v. Brennan replaced the objective component of Redman's deliberate-indifference formulation with an actual-awareness rule for Eighth Amendment prison-conditions claims; Estate of Hunter Bergner v. San Mateo County Sheriff's Office (N.D. Cal.) and the other reviewed lower-court opinions repeatedly recognized that treatment while continuing to apply Redman's unaffected supervisory-policy, personal-participation, and causation rules. One citing order was withdrawn, and the remaining citing opinions either copied a history parenthetical reporting Farmer's act, applied an unaffected Redman rule, or used nearby adverse language for another authority.
781 later cases cite Redman v. County of San Diego; 216 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 Redman v. County of San Diego?
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
Abrogated
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The Supreme Court displaced the objective component of Redman's deliberate-indifference formulation for Eighth Amendment prison-conditions claims, requiring actual awareness and disregard of the substantial risk.
Farmer v. Brennan · Supreme Court of the United States · filed
With deliberate indifference lying somewhere between the poles of negligence at one end and purpose or knowledge at the other, the Courts of Appeals have routinely equated deliberate indifference with recklessness. ... Redman v. County of San Diego, 942 F. 2d 1435, 1443 (CA9 1991) ... That does not, however, fully answer the pending question about the level of culpability deliberate indifference entails, for the term recklessness is not self-defining. ... 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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