The following excerpt is from Croghan v. Branion, No. 2:18-cv-0529 CKD P (E.D. Cal. 2018):
As for claims of verbal abuse, plaintiff is informed verbal abuse and harassment rarely rise to the level of cruel and unusual punishment forbidden under the Eighth Amendment. See Oltarzewski v. Ruggiero, 830 F.2d 136, 139 (9th Cir. 1987) (verbal harassment or abuse by itself is not a constitutional deprivation).
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