The following excerpt is from Coleman v. Brown, 28 F.Supp.3d 1068 (E.D. Cal. 2014):
15. Indeed, in the 1995 order on the merits of plaintiffs' claims the court specifically recognized that [a]pplication of the deliberate indifference standard to this conditions of confinement case in no way precludes application of the malicious and sadistic standard in the context of suits brought by mentally ill inmates for physical or mental injuries sustained by virtue of the need to restore order in an emergency situation. Coleman v. Wilson, 912 F.Supp. at 1323 n. 60.
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