The following excerpt is from O'Sullivan v. Lewis, 972 F.2d 1341 (9th Cir. 1992):
In Hoptowit v. Ray, 682 F.2d 1237, 1246 (9th Cir.1982), we reiterated that a penal institution must provide "adequate food, clothing, shelter, sanitation, medical care, and personal safety." We also noted the need for specificity in actions that challenge conditions of confinement: "To find an Eighth Amendment violation, courts must identify specific conditions that fail to meet Eighth Amendment requirements. We cannot rely on a vague conclusion that the 'totality of conditions' violates the Eighth Amendment." Id. at 1247.
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