## Facts

- Bianca Lucrecia was a transgender woman incarcerated in the federal prison system.
- In January 1986, during Lucrecia’s transition, she was sentenced to 10 years in federal prison.
- Lucrecia was initially assigned to a coed federal prison in California.
- At the California facility, Lucrecia lived in the male section but was permitted to wear female clothing and use female amenities.
- In 1990, Lucrecia was transferred to another coed federal prison in Kentucky and lived in the female section.
- In 1991, Lucrecia was transferred to the Federal Prison Camp in Boron, California (Boron), a lower-security all-male facility.
- At Boron, Lucrecia roomed with three men and was not permitted to wear female undergarments.
- Lucrecia alleged that at Boron she was harassed, assaulted, and abused by other inmates and by prison officials.
- Lucrecia complained to Larry Taylor, the warden at Boron, asking to be treated as a woman; Taylor denied the request.
- Lucrecia then sent a letter to Samuel Samples, the Federal Bureau of Prisons’ western regional director, complaining of unlawful conduct by Boron staff; the letter was forwarded to Taylor, and Lucrecia alleged no action followed.
- Lucrecia sued Samples, Taylor, T. McAfee (associate warden), Captain James Earp, and 20 Doe defendants, alleging (among other things) violations of her right to be free from cruel and unusual punishment.
- The prison officials and Doe defendants moved for summary judgment.

## Issues

1. Whether the alleged harassment, assaults, and abuse at Boron, together with the named officials’ responses to Lucrecia’s complaints, created a triable claim of cruel and unusual punishment under the Eighth Amendment.
2. Whether Lucrecia’s evidence was sufficient to hold supervisory officials liable (including the warden and the regional director) based on their alleged failure to address reported misconduct.
3. Whether the defendants were entitled to summary judgment on the constitutional claims on the record presented.

## Decision

- The court granted summary judgment for the defendant prison officials.
- On the summary-judgment record, the court concluded Lucrecia did not present sufficient evidence to take her Eighth Amendment claims against the named officials to trial.
- The court entered judgment for the defendants on Lucrecia’s constitutional claims addressed in the motion.

## Legal Principles

- An Eighth Amendment conditions-of-confinement or failure-to-protect claim requires evidence of a sufficiently serious risk of harm and that the defendant official acted with deliberate indifference to that risk.
- Liability in a federal constitutional damages action requires personal participation (or a sufficient causal connection) by each named defendant; supervisory status alone is not enough.
- On summary judgment, the plaintiff must produce evidence showing a genuine dispute of material fact; allegations without supporting evidence are insufficient to proceed to trial.
- Courts generally give substantial weight to prison administrators’ housing and security judgments unless the record shows unconstitutional conduct by specific officials.

## Conclusion

In *Bianca Lucrecia v. Samuel Samples, et al.*, a transgender federal inmate challenged her placement and treatment at an all-male prison camp and alleged harassment, assault, and abuse by inmates and staff; after she complained to prison leadership without relief, she sued multiple officials for constitutional violations including cruel and unusual punishment, but the court granted the defendants’ motion for summary judgment based on the evidentiary record.


Bianca Lucrecia v. Samuel Samples, et al., 1995 WL 630016 (1995)