Case Citator › Young, II v. Quinlan

Young, II v. Quinlan

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

Abrogated
Court
Third Circuit
Citation
960 F.2d 351
Decided
Confirmed treatments
2
Flagged citations read
92 of 92
Citing cases (total)
264
Treatment dates
1994–2000
Abrogated
A reviewed court treats this case as abrogated by later authority. Young, II v. Quinlan is abrogated and superseded by statute in part: all 92 flagged citations have been read, with the 2 confirmed treatments listed below. Farmer v. Brennan displaced Young's objective “knew or should have known” test for Eighth Amendment deliberate indifference, requiring subjective awareness of the risk instead.
More on how this was screened

Nyhuis v. Reno held that the Prison Litigation Reform Act eliminated the futility exception and displaced Young's distinction between mixed claims and damages-only claims for exhaustion purposes. The other citing opinions apply Young's surviving holdings, distinguish their facts, or merely repeat Farmer's and the PLRA's effects as citation history.

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.

264 later cases cite Young, II v. Quinlan; 92 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 Young, II v. Quinlan?

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

  • The Supreme Court displaced Young's objective “knew or should have known” deliberate-indifference test and required proof that the prison official was subjectively aware of and disregarded the excessive risk.

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

    We granted certiorari, 510 U. S. 811 (1993), because Courts of Appeals had adopted inconsistent tests for “deliberate indifference.” Compare, for example, McGill v. Duckworth, 944 F. 2d 344, 348 (CA7 1991) (holding that “deliberate indifference” requires a “subjective standard of recklessness”), cert, denied, 503 U. S. 907 (1992), with Young v. Quinlan, 960 F. 2d 351, 360-361 (CA3 1992) (“[A] prison official is deliberately indifferent when he knows or should have known of a sufficiently serious danger to an inmate”). ... 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 →

Superseded by statute

  • The Third Circuit held that the Prison Litigation Reform Act eliminated the futility exception and rendered largely irrelevant Young's distinction between mixed claims and claims seeking only damages.

    Nyhuis v. Reno · Third Circuit · filed

    See Young v. Quinlan, 960 F.2d 351, 356 n. 8 (3d Cir.1992) (Bivens action) (citing Veteto v. Miller, 794 F.2d 98, 100 (3d Cir.1986) (holding “that the requirement for exhaustion of the administrative remedy provided by the [administrative process] applies to a prisoner’s suit for injunctive or mandatory relief whether or not it carries an added claim for damages”)). As explained below, we believe that the PLRA did away with the futility exception altogether. See infra Section I.C. Therefore, the PLRA rendered, for the most part, irrelevant the distinction that Muhammad and Young drew between mixed claim actions and those only involving requests for money damages.
    Read the full opinion on CourtListener →

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