## Facts

- Pearly L. Wilson, an Ohio state prisoner at the Hocking Correctional Facility, sued state prison officials under 42 U.S.C. § 1983 alleging unconstitutional conditions of confinement.
- Wilson alleged conditions including overcrowding, excessive noise, inadequate heating and cooling, and unsanitary facilities.
- Wilson asserted prison authorities were notified of the conditions but failed to take remedial action.

## Issues

1. Whether an Eighth Amendment conditions-of-confinement claim requires proof of a culpable state of mind by prison officials.
2. If so, whether the governing culpability standard is “deliberate indifference” rather than a higher “malicious and sadistic” or similar malice-based standard.
3. Whether the court of appeals erred by applying a “persistent malicious cruelty” standard instead of deliberate indifference.

## Decision

- The Supreme Court held that a prisoner challenging conditions of confinement must prove a culpable state of mind by prison officials.
- The Court held that “deliberate indifference” is the governing subjective standard for conditions-of-confinement claims, not a malice-based standard.
- The Court vacated the judgment and remanded because the court of appeals applied an incorrect, more demanding standard (“persistent malicious cruelty”); the Court could not exclude the possibility that application of the correct standard could change the result.

## Legal Principles

- An Eighth Amendment conditions-of-confinement claim has two components:
  - An objective component: a sufficiently serious deprivation involving the unnecessary and wanton infliction of pain or denial of the minimal civilized measure of life’s necessities.
  - A subjective component: prison officials’ deliberate indifference to inmate health or safety.
- The intent element is tied to the concept of “punishment”; the Eighth Amendment is not satisfied by a purely objective inquiry.
- Deliberate indifference, previously applied to medical-care claims, applies generally to challenges to prison conditions; negligence is insufficient.
- Courts may not require heightened proof of malice (e.g., “persistent malicious cruelty”) for systemic or continuing conditions claims.

## Conclusion

The Court required prisoners challenging confinement conditions to prove both a serious deprivation and officials’ deliberate indifference, and it rejected malice-based standards as too demanding for such Eighth Amendment claims, remanding for reconsideration under the correct test.


Wilson v. Seiter, 501 U.S. 294 (1991)