The following excerpt is from Deere v. Calipatria State Prison Med. Staff, Civil No. 11cv0506 JLS (POR) (S.D. Cal. 2011):
In addition, allegations of overcrowding, without additional facts, are insufficient to state a claim under the Eighth Amendment. See Rhodes v. Chapman, 452 U.S. 337, 348 (1981). Plaintiff alleges events such as wilted lettuce and stale bread. (See FAC at 5.) "[S]ubjection of a prisoner to lack of sanitation that is severe or prolonged can constitute an infliction of pain within the meaning of the Eighth Amendment." Anderson v. County of Kern, 45 F.3d 1310,
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