### FILED U.S. COURT OF APPEALS ELEVENTH CIRCUIT 03/19/99 THOMAS K. KAHN CLERK

1 PUBLISH

IN THE UNITED STATES COURT OF APPEALS
FOR THE ELEVENTH CIRCUIT

________________________ No. 98-8265

________________________ D. C. Docket No. 5:94-CV-345-3(CWH) KIMBERLY CAMPBELL, Plaintiff-Appellant,

versus JAMES SIKES, et al., Defendants-Appellees.

________________________ Appeal from the United States District Court for the Middle District of Georgia

_________________________ (March 19, 1999)
Before COX, CARNES and HULL, Circuit Judges. HULL, Circuit Judge: Plaintiff-Appellant Kimberly Campbell app eals the magistrate judge’s grant of summary judgment for Defendants on her medical-treatment and excessive-force claims under 42 U.S.C. § 1983. After review, we affirm.1 The magistrate judge devoted 43 pages of a 102-page order to giving a detailed summary of Plaintiff’s treatment at GWCI. Ra ther than reiterating the same details, we give only an overview of the facts, highlighting a few representative occurrences of Plaintiff’s selfdestructive behavior and Defendants’ various responses. 2 2 I. FACTS 1 On May 28, 1991, Plaintiff-Appellant Kimb erly Campbell was transferred to the Georgia Women’s Correctional Institution (“GW CI”) to serve five years of a ten-year sentence for distribution of cocaine and interference with government property. Plaintiff’s constitutional claims arise from the medical treatment she received at the GWCI state prison between May 28, 1991, and January 30, 1992.
A. Mental Health Treatment The day Plaintiff arrived at GWCI, sh e was seen by physician Grant Carmichael, who noted that Plaintiff had a history of suicidal threats and had taken psychotropic drugs previously at the Cobb County jail. Carmichael referred Plaintiff to the mental health staff for a mental status exam. That same day, Plaintiff met with ment al health counselor Anne Weathers for a mental status exam. Weathers obtained from Plaintiff extensive details about her psychiatric history, including prior medications, hospitalizations, treatments, and symptoms, and she prepared a three-page report summarizing her observations and findings.2 In the district court, Plaintiff introdu ced medical records showing that between 1982 and 1988, she had been hospitalized thirteen different times seeking treatment for depression, mood swings, suicide attempts, anxiety, paranoia, sleep disturbances, and substance abuse. Although these records show Plaintiff was treated with various medications, including Stelazine and lithium, they show no diagnosis of bipolar disorder–the diagnosis Plaintiff contends Defendants should have made. 3 3 Weathers’s report first details Plainti ff’s own descriptions of her history of alcohol and drug use. Plaintiff admitted using drugs on and off since age thirteen and drinking excessively–as much as a half pint of liquor a day and a quart of beer a day. The report indicates that Plaintiff used marijuana at first, th en beer, Valium, and ultimately “cocaine/crack.” Weathers’s report then focuses on Plainti ff’s psychiatric history. Plaintiff told Weathers that while in school, she received mental health services for “problems with nerves” but no medications. Plaintiff al so reported having a “nervous breakdown” at age eighteen, being hospitalized for a month and a half, receiving Valium, and having a seizure. After release from the hospital, Plaintiff received services in a day hospital for several months. She conti nued to have problems with ne rves and panic attacks, and she got Darvon and Valium from friends to help her cope with these problems. Plaintiff related two suicidal incidents to Weathers: at age nineteen, Plaintiff cut her wrist superficially, and at age twenty-two , she took an overdose of lithium in the presence of her husband’s son. 24 4 Weathers’s report next turns to Plainti ff’s treatment at the Cobb County jail after she was arrested on the cocaine offense. Plaintiff told Weathers that while in the jail, she became anxious, was panicky, heard loud bells ringing in her head, began to sweat, and felt claustrophobic. Plain tiff reported that she was seen by a psychologist and received lithium, Stelazine, Mellaril and Ben adryl. According to Plaintiff’s account, she received mental health care in the ja il because she told jail officials she was thinking of harming herself. Pl aintiff reported that the last four days at the jail, she had not received any medications. Weathers’s report states that she cont acted the Cobb County jail and confirmed that Plaintiff had received the above medications at the jail and that when she left their facility she was taking Trilafon. The jail al so advised that Plaintiff was intoxicated upon admission to the jail, was unstable and began taking off her clothes, and made statements about self injury. The jail pl aced her on suicidal precaution. Weathers’s report relates that the jail officials believed Plaintiff’s suicide threats were a “manipulative ploy” because the jail was reducing her medication: They said that off and on throughout the stay that she did make statements about intent to harm herself, but that it was noted that it appeared to be a manipulative ploy in that they were reducing her medication to stabilize her. They did not consider that she was making a serious suicide threat; however, th ey did place her on suicide watch on several occasions as a precaution.5 5 Weathers’s report also contains Weathers’s own observations from interviewing Plaintiff. According to the report, Plain tiff’s memory was intact for recent and remote events, and there was no evidence Plaintiff was responding to hallucinations. While denying “delusions and grandiose ideation,” Plaintiff reported being anxious, described a fear of being out of control, and request ed to see a doctor to be placed on medication “to help her rest.” Weathers’s report concludes with the following recommendation that Plaintiff be seen by a psychiatrist: Ms. Campbell reports a history of panic attacks and anxiety related symptoms. She also gives a history of suicidal thoughts and manipulative suicidal acts. At the present time, sh e denies intent to harm herself and signs of anxiety. As she was taki ng medication while in the Cobb County jail it is recommended that she be seenby Dr. Sikes to evaluate the need for continuing medication and to make recommendation for treatment. Dr. James Sikes, a psychiatrist, met with Plaintiff on June 3, 1991. Before the meeting, he reviewed Weathers’s report, wh ich he noted specified that Plaintiff had been prescribed psychotropic drugs lithium a nd Trilafon at the Cobb County jail. Sikes noted, too, that Plaintiff had related a long history of intravenous use of cocaine as well as heavy alcohol consumption. His report states that the intermittent anxiety and psychiatric hospitalizations in Weathers’s report appeared to ar ise from complications with drugs and medication. Moreover, Sike s noted that Plaintiff denied having any schizophrenic episodes, auditory hallucinations, or delusional thoughts.6 6 At the meeting with Plaintiff, Sikes obs erved Plaintiff’s current condition. He found her to be calm and cooperative. He saw no evidence of delusional thought or loosening of associations. After meeti ng with Plaintiff and reviewing Weathers’s report, Sikes directed that Plaintiff’s Trilafon be discontinued. Sikes scheduled a follow-up session with Pl aintiff for July 1 in order to observe her behavior once she had been off Trilafon for a few weeks. Sikes’s report from that meeting notes the absence of any reported problems up to that point. The report also states that at the intervie w, Plaintiff told Sikes she had experienced trouble sleeping and “what she consider[ed] as normal adju stment to the prison.” Sikes suggested increased activity but reported “no ev idence of a schizophrenic illness.” Sikes met with Campbell again on August 12. His reports from that meeting indicate he diagnosed Plaintiff as sufferi ng from polysubstance abuse arising from her prior alcohol and drug abuse. Sikes also noted that Plain tiff was “angry and resentful of being called up to talk a bout things” and that she woul d probably “continue to clash with authoritative figures.” His thoughts on Plaintiff’s condition remained unchanged: “I see no indication of schizophrenia or Bipol ar Disorder and will continue to see her as needed should further concerns occur.” Sikes found no indications of schizophrenia (a thought disorder) or bipolar disorder (a mood disorder) because Plaintiff showed “no looseness of associations, no evidence of delusional thought”; he explained, “this7 7 seems to be a failure to adjust to the cond itions of incarceration rather than a presence of a psychiatric illness.” Sikes conclude d that psychotropic medication should not be prescribed absent a diagnosis of mental illn ess. According to Sikes’s reports, he did not prescribe psychotropic medication because he diagnosed Plaintiff as suffering from polysubstance abuse and not a mental illness. Sikes and other mental health professi onals met with Plaintiff numerous times in the months ahead. Sikes himself saw Plai ntiff sixteen times: June 3, July 1, August 12, September 4 or 6, 18, 20, 23, 25, and 30, October 9 and 25, November 1, 8, and 25, December 6, and January 29. In mid-September, when Pl aintiff’s behavior began to deteriorate, Sikes reported, “I t appears that this woman ‘acts strangely’ to get attention or perhaps to earn additional privileges or perhaps to avoid prosecution for her various disciplinaries.” He recommended establis hment and enforcement of clear rules in order to aid Plaintiff in learning to respect and obey authority. Sikes was confident of Plaintiff’s capability to conform her behavior to institutional rules. He thus explained, “She has a temper as many inmates do but she should be held accountable for whatever rules she breaks.” During each meeting withPlaintiff, Sikes continued to find no evidence of a psychiatric illness justifying treatment with medication. Other members of the ment al health staff also me t with Campbell and reached similar conclusions. Plaintiff was placed on the caseload of mental health counselor8 8 Valarie Ford. Ford met with Plaintiff thirty-four times between August 1991 and January 1992: August 1, September 16, 17, 19, 20, 23, 24, 26, and 27, October 10, 14, 15, 16, 21, 22, 23, 24, 25, 27, 28, and 29, November 4, 6, 13, and 19, December 4, 5, 6, 7, 8, 10, 11, and 18, and January 14. Ford reports that she also saw Campbell informally almost every day during that tim e period. According to Ford, from the time of the first meeting she perceived Campbe ll’s behavior as manipulative and saw no evidence of psychosis. After her first meeting with Plaintiff, Fo rd referred Plaintiff to Psychologist Dr. Archer Moore, who also met with Plaintiff on August 1. Moore’s report from that meeting states Plaintiff was “a very angry young woman who de nie[d] any thought of hurting herself.” Moore found “good reality c ontact” but “strong narcissistic features.” During Plaintiff’s stay at GWCI, Moore saw her six times total, (August 1, September 5, 19, 26, and October 10 and 14), and he believed she suffered from a “Narcissistic Personality Disorder” and not a mental illness but stressed that he considered Plaintiff to be primarily Sikes’s patient. No one on the GWCI staff ever diagnosed Plaintiff as suffering from bipolar disorder or prescribed psychotropic medica tions. Instead, the GWCI staff attributed Plaintiff’s behavior to the lingering effects of her prior substance abuse, the difficulties9 9 of adjusting to life in prison, and, on some occasions, deliberate a ttempts to manipulate officials.
B. Restraints During June, July, and August 1991, Plai ntiff was sanctioned a few times for minor disciplinary infractions. In Septem ber 1991, however, Plaintiff began engaging in defiant behavior that even tually became violent, self-des tructive, and even suicidal. On several occasions, she thrashed about her cell, climbed up on the sink, ripped her sheets to shreds, beat on and dismantled th e overhead light, and attempted to obtain sharp objects. Plaintiff also bit and scratc hed prison officials and threatened to “hurt someone.” Plaintiff often threatened to flood the toil et, which posed a security risk because it could mandate evacuation of other ce lls in the unit. In addition, Plaintiff started multiple fires in her cell, burning her food tray, her Bible, her clothing, and other such items. One clothing fire she started caused her entire cellblock to be evacuated. Prison officials responded by rem oving potentially harmful belongings, instituting terms of solitary confinement, and restraining Plaintiff using several forms of restraint. Officials gradually increa sed the level of restraint. They used straightjackets on several occasions, which ma de Plaintiff’s hands unusable but left her able to walk around the cell. On at leas t one occasion when officials used only a3 Plaintiff calls it “hog-tying,” and Defendants call it “tethering.” We refer to it as the “L” shape method of restraint. 10 10 straightjacket, Plaintiff began banging her head and kicking. When Plaintiff’s behavior escalated, officials also used “four-point re straints” at least five times, anchoring each of her arms and legs to a different point on the bed. Throughout her stay at GWCI, Plainti ff demonstrated an uncanny ability to escape from most forms of restraint. She removed her straightjacket on numerous occasions, and at least once, she freedherself from four-point restraints. Plaintiff’s complaint, however, focuse s mainly on the in stances in which officials employed a third method of restraint that left her in an “L” shape 3 with her knees bent so that her calve s were perpendicular to her back. To use this form of restraint, officials first immobilized Plaintiff’s hands and arms using either a straightjacket or handcuffs behind her back. Next, they put handcuffs on her ankles. Finally, they used a strap that ran the length from the handcuffs on her ankles up to the handcuffs on her wrists. This left Plain tiff in an “L” shape, with her body from her head to her knees defining the vertical part of the “L” and th e lower portion of her legs–from her knees along her calves to her feet–defining the horizontal portion of the “L.” This “L” shape restraint would have resulted in Plaintiff’s being in a kneeling position had she been left upright. Most of the time, she was lying on her side with the11 11 “L” shape on a plane parallel to the ground. On at least one occasion, Plaintiff freed herself from the leg tether while this “L” shape form of restraint was being used. Although Plaintiff entered GWCI in May 1991, Sikes first ordered Plaintiff restrained using this “L” shape method on September 18, 1991. On September 17, Plaintiff was observed standing on the bed w ith a sheet wrapped around the back of her neck. Believing Plaintiff might be trying to commit suicide, mental health staff removed her clothing and othe r belongings, placed her in seclusion, conducted security checks every fifteen minutes, and monitored her condition using a camera. The next morning, Plaintiff was sent to Sikes for evaluation. She yelled at Sikes, turned over a table, and broke a phone. When Plaintiff was returned to seclusion and ordered to strip in front of male guards, she refused. Upon a second request, she complied but began running around the cell, ki cking and butting the wall. Officials then contacted Sikes, who ordered Plaintiff placed in a straightjacket, which immobilized her hands and arms. Shortly thereafter, Plaintiff began banging her head and kicking. When informed of this behavior, Sikes ordered that Plaintiff be placed in a helmet and that the “L” shape restrain t be employed. This immobilized her legs as well as her arms, preventing her from jumping, climbing, kicking, and running around the cell.4 Plaintiff actually alleges “at least five tim es.” Undisputed facts include five clear instances of the “L” shape restraint and other tim es when the exact type of restraint used is unclear.

5 Although we describe only the first use of the “L”shape restraint, the magistrate judge’s order details all five occurrences and Plaintiff’s violent and often self-destructive behavior precipitating the use of the “L” shape restraint. The approximate periods of the “L” shape restraint are (1) from 10:05 a.m. on September 18 to 1:05 p.m. on September 19; (2) from 10:20 p.m. to 11:45 p.m. on September 22; (3) from 9:45 p.m. on October 12 to 2:45 a.m. on October 13; (4) from 10:05 p.m. on October 23 to 2:15 p.m. on October 24; (5) from 3:30 p.m. on October 25 to 10:10 a.m. on October 28. During these periods of restraint, Campbell was reevaluated every twenty-four hours and left in restraints only if her self-injurious inclinations were still apparent. For example, restraints were continued during the longest (almost 67-hour) period of restraint because Campbell threatened to drink Clorox if the restraints were removed. 12 12 Between September 18 and Oc tober 28, officials restrained Plaintiff using this “L” shape method five times. 4 In addition to the twenty-seven hours on September 18 to 19, the “L” shape restraints were app lied for about one hour and twenty-five minutes on September 22, five hours on October 12 to 13, sixteen hours on October 23 to 24, and sixty-six hours and forty minutes on October 25 to 28. 5 Although the restraints undoubtedly caused physical discomfort and emotional pain, they undisputedly caused Plaintiff no physical injury. It is also undisputed that officials monitored Plaintiff’s physical cond ition while she was restrained. Plaintiff’s circulation was checked each time the “L” sh ape method of restraint was applied, and security officers checked her every fifteen minutes while she was restrained. Medical staff also provided regular checks; a nurse assessed Plaintiff’s condition every few hours, and a doctor reevaluated the need for restraints every twenty-four hours.13 13 On at least two occasions, Defendant Sikes declined to approve restraints requested by other officials. Plaintiff admits that on each of these occasions, Sikes explained to the requesting officers that restra ints were inappropriate when Plaintiff did not pose an immediate threat to her own safety. Although used five times between Septem ber 19 and October 28, the “L” shape restraints were not used during N ovember and December 1991 or January 1992. Plaintiff asserts the “L” shape restraints were discontinued because a prison deputy commissioner had issued an edict proscribing “hogtying.”
C. Outside Evaluation s In December 1991, Plaintiff requested to be taken off the mental health caseload. The staff conferred and determined that Plai ntiff did not have an Axis I diagnosis and that she would still have a counselor and access to mental health se rvices as needed in the general population. Thus, they grante d her request and reassigned her to the general population on December 31. On January 28, 1992, Plaintiff was placed infour-point restraints for setting four fires and breaking the lights in her cell. On January 29, Plaintiff wrapped torn strips from her jumpsuit around her neck in an attemp ted suicide. The ne xt day officials sent her to a forensic mental health unit at Cen tral State Hospital for additional psychiatric14 14 evaluation. Doctors there diagnosed Plaintiff as suffering from bipolar disorder and prescribed the psychotropic medications lithium and Mellaril. Plaintiff was returned to GWCI for th e remainder of her incarceration. Because Sikes was no longer working at GWCI, Plain tiff was evaluated by Dr. Richard Panico, who had just begun working as a part-time consulting psychiatrist at GWCI. Dr. Panico diagnosed Plaintiff as suffering fro m bipolar disorder and prescribed lithium. Plaintiff was paroled in March 1993. After her release, Plaintiff was admitted to Georgia Regional Hospital in February 1994. The Georgia Regional Hospital records indicate that the February admi ssion was due to “a serious overdose on lithium” and that Plaintiff had “a past history of suicidal threats.” Plaintiff was admitted again to Georgia Regional Hospital for reevaluation and treatment on April 28, 1994. At this admi ssion, psychological testing was done to aid in evaluating Plaintiff. The Georgia Regiona l Hospital records reveal that Plaintiff was diagnosed as presenting a “personality disord er,” “with borderline anti-social features, and an Axis I diagnosis of alcohol and substance abuse.” At Georgia Regional Hospital, the treating psychiatrist specifica lly noted that “Plaintiff did not present an Axis I diagnosis of bipolar disorder.”
II. PROCEDURAL HISTORY A. Complaint15 15 Plaintiff filed a complaint in state court in nine counts: (1) a § 1983 claim for deliberate indifference to serious medical needs; (2) a § 1983 claim for cruel and unusual punishment through use of stripping, restraint, and isolation; (3) a § 1983 claim for excessive force; (4) a § 1983 s ubstantive-due-process claim for punishment in lieu of treatment; (5) a § 1983 claim allegi ng infringements of Plaintiff’s proceduraldue-process and First Amendment rights; (6) a claim under the Georgia Tort Claims Act (“GTCA”) for medical and professi onal negligence; (7) a GTCA claim for intentional infliction of emotional distress; (8) a GTCA claim for neligence and intentional infliction of emotional distre ss against Sikes and Moore as independent contractors; and (9) a claim alleging violations of the Georgia Constitution and a Georgia statute regarding types of punishment. The five defendants in Plaintiff’s initial complaint were the Georgia Department of Corrections (“GDOC”), Mental Health Director Albert Duncan, PsychiatristJames Sikes, Psychologist Archer Moore, and Warden Art Gavin. Defendants removed to federa l court in the Northern District of Georgia. In federal court, Plaintiff filed her first amended complaint, which incorporates the claims in the initial complaint and a dds Mental Health Counselor Valarie Ford as a Defendant. The district court granted Plaintiff’s motion to amend.16 16 The district court also granted in part Plaintiff’s motion to remand to state court, remanding all claims against the GDOC and any official-capacity claims against Duncan, Sikes, Moore, Gavin, and Ford. Thus, remaining in federal court were Plaintiff’s individual-capacity claims agains t Duncan, Sikes, Moore, Gavin, and Ford. B. Motions for Summary Judgment After Defendants’ motion for a transfer to the federal court in the Middle District of Georgia was granted, the parties consented to proceedi ng before a magistrate judge and began discovery. Defe ndants filed separate motions for summary judgment, arguing Plaintiff had failed to allege a c onstitutional violation and asserting qualified immunity. C. Magistrate Judge’s Order On January 28, 1998, the magistrate judge issued an order (1) granting Defendants Sikes, Moore, Gavin, and Ford summary judgment based on qualified immunity on all five of Plaintiff’s § 1983 claims; (2) granting those Defendants summary judgment on any Georgia Tort Claims Act claims still in federal court; and (3) with Plaintiff’s consent, dismissing Duncan as an improper party. D. Scope of This Appeal Plaintiff’s appeal challenges only the magistrate judge’s grant of summary judgment on her § 1983 claims against Defenda nts Sikes, Moore, Gavin, and Ford.6 To the extent that Plaintiff appeals other claims and issues, we find no reversible error in the decision of the magistrate judge. See 11th Cir. Rule 36-1. 17 17 Plaintiff does not appeal the dismissal of Defendant Duncan or the grant of summary judgment for Defendants on any Georgia Tort Claims Act claims remaining in federal court. Plaintiff also abandons certain constitutional violations alleged in her first amended complaint. She primarily focuses on two distinct alleged violations of the Eighth Amendment: (1) Defendants’ deliberat e indifference to serious medical needs, and (2) Defendants’ excessive force. Thus, on appeal, we discuss whether th e magistrate judge erred in granting summary judgment for Defendants Sikes, M oore, Gavin, and Ford on Plaintiff’s § 1983 claims for deliberate indifference to serious medical needs and for use of excessive force. 6 III. REVIEW OF SUMMARY JUDGMENT BASED ON QUALIFIED IMMUNITY We review the magistrate judge's grant of summary judgment de novo . Steele v. Shah , 87 F.3d 1266, 1269 (11th Cir. 1996). In doing so, we “evaluate the summary judgment record in the light most favorable to . . . the nonmovant ,” and we will affirm the district court’s grant of summary judgm ent only if the recorddemonstrates that there was no genuine issue of material fact and that Defendants were entitled to judgment as a matter of law. Id. ; Fed. R. Civ. P. 56.7 See also Crawford-El v. Britton , 118 S. Ct. 1584, 1586 (noting that when a claim requires “proof of wrongful motive,” it may be preferable to begin summary judgment analysis by examining the proof of intent because “the immunity question . . . sometimes requires complicated analysis of legal issues”). 18 18 The magistrate judge’s order and the parties’ briefs focus almost exclusively on qualified immunity and the question of whethe r, at the time of Defendants’ actions, the law clearly established that Plaintiff’s rights were being violated. We turn first to an alternate basis for summary judgment, inquiring whether this record contains any evidence of an underlying constitutional viola tion. Because Plaintiff’s evidence would not support a reasonable jury’s finding that Defendants violated Plaintiff’s constitutional rights, we need not address the applicability of qualified immunity. See Killian v. Holt , — F.3d —, No. 97-6802 (11th Cir. Feb. 4, 1999) (affirming district court's entry of summary judgment for defe ndants without qualified immunity analysis because plaintiff “failed to bring forth evidence from which reas onable jurors could find that defendant prison officials knew of and were deliberately indifferent to a substantial risk of serious harm”); Hale v. Tallapoosa County , 50 F.3d 1579, 1582 (11th Cir. 1995) (affirming summary judgmen t for one defendant without relying on qualified immunity because the plaintiff’s evidence was “insufficient to support the level of deliberate indifference and causal connection necessary”); 7 see also Cottrell v. Caldwell , 85 F.3d 1480, 1489-92 (11th Cir. 1996) (in an interlocutory appeal of the district court’s denial of summary judgment, turning first to plaintiff’s evidence of the8 We observe that this case–unlike Cottrell and Adams –is an appeal from a final judgment, where there is no dispute that we can examine first whether there is sufficient evidence to support a reasonable jury’s finding a constitutional violation. However, Cottrell and Adams show that even in interlocutory appeals limited strictly to qualified immunity issues, the same procedure is permissible. In another qualified immunity interlocutory appeal, Dolihite v. Maughon , 74 F.3d 1027 (11th Cir.) cert. denied , 117 S. Ct. 185 (1996), this Court again focused on the “predicate element of the underlying constitutional tort,” which is “part and parcel of the core qualified immunity issue which is immediately appealable.” Id. at 1033 n.3. Even if identification of the precise knowledge of each de fendant is not “part and parcel of the core qualified immunity issue,” it is “‘inextricably intertwined’ with the core issue and thus would be immediately appealable.” Id. 19 19 constitutional violation itself and holding, “p laintiff has failed to show a violation of due process, and it necessarily follows that the defendants are entitled to summary judgment on qualified immunity grounds”); Adams v. Poag , 61 F.3d 1537 (11th Cir. 1995) (in another interlocutory appeal of a district court’s denial of summary judgment, holding defendants were entitled to summary judgment based on qualified immunity because plaintiffs had failed to present evidence of deliberate indifference to support their Eighth Amendment claim). 8
IV. EIGHTH AMENDMENT The Eighth Amendment governs the conditions under which convicted prisoners are confined and the treatment they receive while in prison. Farmer v. Brennan , 511 U.S. 825, 832 (1994) (quoting Helling v. McKinney , 509 U.S. 25, 31 (1993)); see also Whitley v. Albers , 475 U.S. 312, 327 (1986) (holding that “the Due Process Clause affords . . . no greater protection”). Although the Constitution does not require comfortable prisons, it does not permit inhumane ones. Farmer , 511 U.S. at 83220 20 (quoting Rhodes v. Chapman , 452 U.S. 337, 349 (1981)). Still, the Eighth Amendment does not authorize judicial reconsideration of “every governmental action affecting the interests or well-being of a prisoner,” Whitley , 475 U.S. at 319; instead, “‘[a]fter incarceration, only the “‘unnecessary and wanton infliction of pain’”. . . constitutes cruel and unusual punishment forbidden by the Eighth Amendment.’” Id. at 319 (quoting Ingraham v. Wright , 430 U.S. 651, 670 (1977) (quoting Estelle v. Gamble , 429 U.S. 97, 103 (1976) (citations omitted))). Crucial to establishing an “unnecessary and wanton infliction of pain” is some proof that officials acted with specific inte nt. This specific-intent requirement for an Eighth Amendment violation applies to both failure to provide proper medical care, Steele v. Shah , 87 F.3d 1266, 1269 (11th Cir. 1996) , and excessive force, see Whitley , 475 U.S. at 319-21. However, the exact natu re of the specific intent required depends on the type of claim at issue. Whitley , 475 U.S. at 319. Thus, we address each claim in turn.
V. “DELIBERATE INDIFFERENCE” TO SERIOUS MEDICAL NEEDS The Eighth Amendment’s proscription of cruel and unusual punishments prohibits prison officials from exhibiting de liberate indifference to prisoners’ serious medical needs. Estelle v. Gamble , 429 U.S. 97, 104 (1976). The Supreme Court has been careful to note, however , that “a complaint that a physician has been negligent in21 21 diagnosing or treating a medical condition does not state a valid claim of medical mistreatment under the Eighth Amendment.” Id. at 106. Thus, in Estelle v. Gamble , which first enunciated the “deliberate i ndifference” standard, the Supreme Court reinstated the district court’s dismissal of a prisoner’s § 1983 complaint for failure to state a claim. Noting that the complaint’ s primary allegation was that “more should have been done” to diagnose a nd treat a back injury, the Court explained, “A medical decision not to order an X-ray, or like m easures, does not represent cruel and unusual punishment. At most it is medical malpractice.” Id. at 107. Subsequent Supreme Court cases have re fined the inquiry. In Wilson v. Seiter , 501 U.S. 294 (1991), the Supreme Court explained that the Eighth Amendment applies only to punishments and that prison conditions are only punishment if a mental element of punitive intent is shown: The source of the intent requirement is not the predilections of this Court, but the Eighth Amendment itself, which bans only cruel and unusual punishment. If the pain inflicted is not formally meted out as punishment by the statute or the sentencing judg e, some mental element must be attributed to the inflicting officer before it can qualify. Id. at 300. Although the very imposition of a certain term in prison is punitive, the punitive purpose of the sentence itself does notconvert every attribute of the place of incarceration into a punishment subject to Eighth Amendment scrutiny. Thus, conditions of confinement violate the Eighth Amendment only if they (1) rise to the22 22 level of a “serious” deprivation; and (2 ) result from the official’s “deliberate indifference.” Id. at 297-99. Wilsonand subsequent cases re fer to these two required elements as an “objective component” sc rutinizing the allege d deprivation and a “subjective component” examining the official’s mental intent.
A. Farmer v. Brennan Requires Proof Of Subjective Mental Intent Most recently, in Farmer v. Brennan , 511 U.S. 825 (1994), the Supreme Court explained further the requisite “subjectiv e component” of a conditions-of-confinement claim and defined the exact subjective mental state required for “deliberate indifference,” as follows: [A] prison official cannot be f ound liable under the Eighth Amendment for denying an inmate humane conditions of confinement unless the official knows of and disregards an excessive risk to inmate health or safety; the official must both be aw are of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference. This approach comports be st with the text of the Amendment as our cases have inte rpreted it. The Eighth Amendment does not outlaw cruel and unusual "c onditions"; it outlaws cruel and unusual "punishments." An act or omission unaccompanied by knowledge of a significant risk of harm might well be something society wishes to discourage, and if harm does result society might well wish to assure compensation. The common law reflects such concerns when it imposes tort liability on a purely objectiv e basis. But an official's failure to alleviate a significant risk that he should have perceived but did not, while no cause for commendation, cannot under our cases be condemned as the infliction of punishment. Id. at 837-38 (emphasis added) (internal cita tion omitted). Thus, in light of Farmer , liability may be imposed for deliberate indifference only if the plaintiff proves the23 23 defendant actually knew of “an excessive ri sk to inmate health or safety” and disregarded that risk. Id. at 837. Proof that the defe ndant should have perceived the risk, but did not, is insufficient. Id. at 838; Cottrell v. Caldwell , 85 F.3d 1480, 1491 (11th Cir. 1996) (“There is no liability for ‘an official’s failure to alleviate a significant risk that he should have perceived but did not . . . .’” (quoting Farmer , 511 U.S. at 838)). Thus, the official must have a s ubjectively “‘sufficiently culpable state of mind.’” Cottrell , 85 F.3d at 1491 (quoting Farmer , 511 U.S. at 834). This “requirement follows from the principl e that ‘only the unnecessary and wanton infliction of pain implicates the Eighth Amendment.’” Farmer , 511 U.S. at 834 (quoting Wilson , 501 U.S. at 297).
B. Post-Farmer Decisions This Court recently applied Farmer in the psychiatric me dical needs context in Steele v. Shah , 87 F.3d 1266 (11th Cir. 1996). In Steele , a Florida inmate claimed that a prison psychiatrist was deliberately indifferent in discontinuing prescribed psychotropic medication. The Steele Court explained that under Farmer , summary judgment must be granted for the defendant official unless the plaintiff presents evidence of the official’s subjective knowledge , as follows: since a finding of deliberate indifference requires a finding of the defendant's subjective awareness of th e relevant risk, Farmer v. Brennan , 511 U.S. 825, ----, 114 S. Ct. 1970, 1979, 128 L.Ed.2d 811 (1994), a genuine issue of material fact exists only if the record contains evidence,24 24 albeit circumstantial , Farmer , 511 U.S. at ----, 114 S. Ct. at 1981, of such subjective awareness . See Cottrell v. Caldwell , 85 F.3d 1480, 1491 (11th Cir.1996) (acknowledging Farmer's requi rement of subjective awareness and rejection of a solely objective test of deliberate indifference). Id. at 1269 (emphasis added). This subjective knowledge was evidenced in Steele by the underlying facts and circumstances of the case. The plaintiff had been prescribed psychotropic medications at a previous institution. Id. at 1267. When the plaintiff was transferred to a new prison, the defendant, Dr. Shah, saw the plaintiff for “less than one minute” and discontinued psychotropic medications. Id. Shah did not review any medical records other than the Treatment Plan listing medications prescribed by the prior institution, and he did not consult withany medical staff. Id. After Shah discontinued the plaintiff’s medication, medical staff from the prior institution wrote the new prison expressing concern that the plaintiff was a suicide risk, had been on psychotropic medication, and was not now receiving his medication. Id. at 1268. Their letters clarified that the plaintiff had been diagnosed as having “Adjustment Disorder with Anxious Mood,” needed psychotropic medicati on, had tried suicide twice, and was considered a suicide risk. Id. at 1267-68. Still, Shah did not respond; the plaintiff continued without psychotropic medication for the duration of his time at the new prison. Id.25 25 This Court held that a jury would be entitled to find that Shah had discontinued the plaintiff’s medication “on the basis of one cursory intervie w and without having reviewed any medical records beyond the Treatment Plan sent over from the Polk facility.” Id. at 1270. The Court continued thata jury could further find that Shah “‘knew of a substantial risk from the very fact that the risk was obvious,’” that Shah “deliberately disregarded that risk,” and th at Shah “was aware from Polk personnel that Steele was considered by them to be a potentia l suicide risk, and that that was one basis for their prescription of the psychotropic drugs.” Id. (quoting Farmer , 511 U.S. at 842). The Steele Court noted that this circuit’s tw o most directly relevant precedents both pre-dated Farmer . Id. at 1269 n.2 (citing Greason v. Kemp , 891 F.2d 829 (11th Cir. 1990); Waldrop v. Evans , 871 F.2d 1030 (11th Cir. 1989)). However, the Steele Court found that Farmer did not necessarily affect the holdings in those two pre-Farmer cases, stating “Greason(surely) and Waldrop (almost as surely) based their specific holdings on the existence of eviden ce of subjective awareness.” Id. We understand Steele ’s equivocation about Waldrop ’s holding because Waldrop discusses only what9 Waldrop never addresses whether there is sufficient evidence for a reasonable jury to find the defendants knew their case was grossly inadequate. Instead, Waldrop inquires whether there is evidence that the defendants’ actions we re grossly incompetent and violated professional standards, and it focuses on what a reasonable person in the defendants’ position would have known. Waldrop , 871 F.2d at1034-36. Thus, Steele was correct in hesitating to rely on Waldrop ’s assessment of the evidence now that Farmer has clarified the subjective-intent requirement. Steele , 87 F.3d at 1269 n.2. Like the Steele Court, we focus instead on Greason

.
10 We question Steele ’s characterization of Greasonas basing its holding on evidence of subjective awareness. Greasonis a pre-Farmer case that does not purport to apply the Farmer subjective prong. Instead, Greasonexamines the evidence of deliberate indifference in the context of an objective qualified immunity analysis. Although Greason does state, “we believe that a trier of fact could find that Dr. Fodor provided such care [grossly inadequate psychiatric care] and, moreover, that he realized that he was doing so at the time,” id. at 835, the ultimate holding in Greasonis that “a jury could find (1) that Dr. Fodor provided grossly inadequate care and (2) that a reasonable personin Dr. Fodor’s position would have known that the care delivered constituted deliberate indifference to Greason ’s Eighth Amendment rights.” Id. (emphasis supplied). Nonetheless, we are not required to resolve whether Steele correctly characterizes Greason ’s holding, the precedential effect of Steele ’s statements about and reliance on preFarmer Greason , or whether the facts of Greasonwould have met the Farmer test because, in any event, Greason ’s facts are readily distinguishable from those in this case. 26 26 a reasonable person would ha ve known–an objective test. 9 However, we do examine
Greasonin detail because Steele relies so heavily on Greason

. 10
In Greason , the inmate’s prior therapist at Gwinnett County Mental Health Center had sent a letter to the prison docto r describing the inmate’s current mental status, relating his history of mental illne ss, and noting that he had been hospitalized thirteen times and diagnosed as a “schiz ophrenic” with suicidal tendencies. Id. at 831- 32. The therapist urged continuation of the inmate’s medication for his diagnosed mental illness and close monitoring. Id. The inmate’s psychiatrist at the Georgia Department of Human Resources also sent a letter reporting that the inmate continued11 Later, the inmate’s parents visited the inmate in prison and reported to an assistant who worked under the psychiatrist’s supervision that the inmate had suicidal thoughts. Fearing the inmate might attempt suicide again, the parents urged the assistant to have the inmate transferred to a hospital. The assistant did nothing and did not contact the psychiatrist. Twenty-four days later, the inmate hung himself. Id. at 832-33. 27 27 to have suicidal thoughts and needed to be maintained on his medication. Id. at 832. Both letter reports were in the inmate’s clinical file. Id. Two and a half months after the inmate’s arrival, the prison psychiatrist saw him for a few minutes, promptly concluded that his condition had stabilized, and discontinued his medications without reviewi ng the clinical file or assessing his mental status to determine his potential for suicide. About a month later, the psychiatrist saw the inmate again for only a few minutes. 11 Based on these facts, the GreasonCourt found that there was sufficient evidence from which a jury could conclude that the psychiatrist provided grossly inadequate me dical care “and, moreover, that he realized that he was doing so at the time .” Id. at 835 (emphasis supplied). The parties also cite other post-FarmerEleventh Circuit decisions involving deliberate indifference to an arrestee’s or an inmate’s non-psychiatric medical needs. See, e.g. , Lancaster v. Monroe County, Ala. , 116 F.3d 1419, 1426-27 (11th Cir. 1997) (involving a chronic alcoholic dying from a withdrawal-induced seizure while in pretrial detention after his wife warnedjailers about his chronic alcoholism and propensity for life-threatening seizures as he withdraws, directly applying Farmer , and12 Although post-Farmer , Adams does not cite or discuss Farmer , but it nonetheless stresses that in this Circuit “cases have consistently held that knowledge of the need for medical care and an intentional refusal to provide that care constitutes deliberate indifference.” 61 F.3d at 1543 (emphasis supplied). 28 28 holding sufficient evidence presented from wh ich a jury could find that each defendant “knew [the decedent] had urge nt medical needs that would be significantly exacerbated by delay,” that each defendant “planned to keep [the deced ent] in jail without medical supervision or treatment until he had a seiz ure,” and each defendant “delayed obtaining treatment for [the decedent] until after he suffered a seizure”); Cottrell v. Caldwell , 85 F.3d 1480, 1490-91 (11th Cir. 1996) (involving an arrestee dying from positional asphyxia while in a police car , directly applying Farmer , and holding no evidence to support a jury finding that defendant police officers “were consciously aware of and disregarded the risk that [decedent arrestee] would suffocate” as a result of defendants’ positioning and restraining decedent arre stee in police car); Adams v. Poag , 61 F.3d 1537, 1543-48 (11th Cir. 1995) (involving inmate with acute asthma and inability to breathe, reversing the denial of qualified immunity, and holding that evidence created fact issues regarding medical malpr actice but not deliberate indifference). 12 Although helpful guidance, these three decisions do not involve deliberate indifference to13 The parties also cite this Court’s post-Farmer decisions in Dolihite v. Maughon , 74 F.3d 1027 (11th Cir. 1996), and Hale v. Tallapoosa County , 50 F.3d 1579 (11th Cir. 1995). However, we focus on Steele as it involves the subjective element of deliberate indifference (as opposed to the objective qualified immunity analysis in Dolihite ) and psychiatric medical needs (as opposed to inmate-on-inmate violence in Hale ), and we discuss Greasonbecause of Steele ’s reliance on it. Dolihite concerns a juvenile who hung himself while involuntarily civilly committed at a state psychiatric facility, but the majority opinion does not cite Farmer or discuss the subjective prong outlined in Farmer . Instead, the majority opinion in Dolihite addresses only the objective prong of qualified immunity–whether “a reasonabl e professional in defendant’s shoes would have known that his challenged actions (or inacti on) violated plaintiff’s constitutional rights.” Id. at 1046. In Hale , the plaintiff arrestee sued for damages arising from being beaten by other occupants of an overcrowded, small “bullpen” with detainees not segregated based on proclivity for violence or reasons for confinement. 50 F.3d at 1580-81. The case turned on whether defendants knew about the significant risk of inmate-on-inmate violence but knowingly disregarded that risk and kept the plaintiff arrestee in that bullpen. Id. at 1582-84. The Court stressed the evidence that officials admitted knowing that inmate-on-inmate violence occurred in that overcrowded “bullpen” on a regular basis and resulted in injuries requiring medical treatment. Id. at 1583. 29 29 psychiatric medical needs. Thus, we have focused instead on Steele and Greason , which do. 13
C. Plaintiff’s Contentions We now apply the teachings of Farmer , Steele , and Greasonto this case. Plaintiff contends that Defendants’ medi cal care was grossly inadequate and that Defendants knew their care was grossly inad equate. According to Plaintiff, the medical care Defendants provided was gr ossly inadequate because Defendants misdiagnosed her as having a polysubstance abuse disorder when they knew or should have known she had bipolar disorder, discon tinued medication that would have treated her bipolar disorder, improperly used behavior modification techniques, and waited30 30 eight months before sending her outside the prison for diagnostic tests. Plaintiff also submits expert testimony sta ting Defendants’ medical care was grossly inadequate, while Defendants’ experts st ate Defendants complied with the applicable standard of

care. After review, we agree with the magistra te judge that Plaintiff has presented insufficient evidence for a r easonable jury to find that Defendants knew that she had bipolar disorder, that Defendants knew th ey had misdiagnosed her as suffering from polysubstance abuse rather than bipolar di sorder, or that Defendants otherwise knew their treatment was grossly inadequate but proceeded with the treatment anyway. Without evidence to establish the subjec tive mental intent prong of deliberate indifference, Defendants are entitle d to summary judgment under Farmer . We address Plaintiff’s evidence agains t each Defendant in turn.
D. Defendant Sikes Defendant Sikes is a psychiatrist who work ed part time at GWCI. Sikes first met with Plaintiff on June 3, 1991, a few days af ter her transfer to GW CI, and he gave the order to discontinue her psychotropic medica tion. Sikes himself saw Plaintiff sixteen times during the eight months before he de termined that she needed to go to Central for further mental health examination. Sike s was also consulted by mental health staff31 31 on numerous other occasions, and he was rep eatedly called upon to advise correctional officers on how to respond to Plaintiff’s self-destructive behavior. Sikes’s liability turns on whether he knew Plaintiff had bipolar disorder, or knew he was misdiagnosing Plaintiff, or knew his treatment was otherwise grossly inadequate but proceeded with the treatment anyway. Sikes’s reports show he diagnosed Plaintiff as suffering from polysubstance abuse, and Plaintiff agrees that psychotropic medication is not proper treatment for polysubstance abuse. Plaintiff’s complaint asserts principally that Sikes misdiagnosed her condition, that she had bipolar disorder rather than merely su ffering from polysubstance abuse, that her behavior made it obvious that she had bipol ar disorder, and that Sikes should have known both that she was bipolar and that medication was the proper treatment for bipolar disorder. In addition, Plaintiff argues any treatment she did receive was both grossly inadequate and detrimen tal to her bipolar condition. 1. Facts Regarding Sikes’s Treatment Sikes is entitled to summary judgment on Plaintiff’s deliberate-indifference claim because Plaintiff faile d to present evidence from wh ich a reasonable jury could infer that Sikes knew she had bipolar disord er, or knew he was misdiagnosing Plaintiff, or knew his treatment was otherwise gro ssly inadequate but proceeded with the treatment anyway. See Steele , 87 F.3d at 1269; Greason , 891 F.2d at 835. Turning14 Sikes says he also performed an independentreview of Plaintiff’s history, but Plaintiff disputes that. We thus rely only on Sikes’s personal interview of Campbell and his review of Weathers’s report. 32 32 first to the initial diagnosis and discontinua tion of medication, the undisputed evidence shows that Sikes discontinued Plainti ff’s medication only after Sikes personally interviewed Plaintiff and reviewed a three-page report by Weathers, who had performed an extensive review of Plaintiff’s history and symptoms. 14 It is also undisputed that Sikes, unlike the psychiatrists in Steele and Greason , conducted multiple follow-up sessions and observed Plain tiff’s behavior repeatedly once she was off medication; altogether, he met with Campbell sixteen times. Moreover, Weathers’s report revealed the Cobb County jail told We athers that Campbell’s suicidal threats might be an attempt to manipulate officials as they were reduci ng her medication. In stark contrast, the professionals previously responsible for the plaintiff inmates in Steele and Greasonstressed the inmates’ suicidal tendencies and prior psychiatric diagnoses and urged continued medication. Plaintiff faults Sikes for not obtaining and reviewing her actual medical records from the Cobb County jail or her prior thirteen hospitalizations as a juvenile. However, Sikes reviewed (a) Weathers’s detailed summary of Weathers’s communications with the Cobb County jail, which included an account of Campbell’s symptoms and treatment at the jail, and (b) Weathers’s summary of Plaintiff’s personal33 33 history, which included an account of mental health problems as a juvenile and a prior hospitalization. Moreover, the jail r ecords and prior hospitalization records themselves, which are in eviden ce in this case, contain no diagnosis of bipolar disorder. Plaintiff also points to the fact that Sikes did know she was prescribed Trilafon and lithium while at the Cobb County jail, which she says shoul d have put Sikes on notice she had bipolar disorder. However, the Cobb records themselves show Plaintiff was placed on Trilafon and lithium without indi cating a diagnosis of bipolar disorder. Indeed, in an affidavit, Dr. Youngleson, who prescribed the medication at the jail, testifies (1) that Plaintiff was never given any diagnosis while at the jail; (2) that looking back, he believes Plaintiff suffere d from a personality disorder rather than bipolar disorder; and (3) that Plaintiff’s threats and self-destructive behavior seemed manipulative. The jail records also showCobb County jail officials’ concerns that Plaintiff might be “running a game on us” and acting out to manipulate officials. Sikes’s ongoing medical treatment is also readily distinguishable from that in Steele and Greason , where the psychiatrists basically did nothing to treat the inmates after discontinuing their medication. See Adams v. Poag , 61 F.3d 1537, 1544 (11th Cir. 1995) (noting that “when the need fo r medical treatment is obvious, medical care that is so cursory as to amount to no treatment at all may constitute deliberate indifference”). In stark contrast, Sikes spen t a great deal of time and effort working15 As noted above, Plaintiff was placed on the caseload of mental health counselor Valarie Ford. Ford conducted 34 counseling sessions with Plaintiff and saw Plaintiff informally on a near daily basis.

16 Such actions also readily distinguish this case from the deliberate refusal to give the pre-trial arrestee any medical treatment in Lancaster v. Monroe County, Ala. , 116 F.3d 1419, 1426-27 (11th Cir. 1997). 34 34 with Plaintiff. Sikes also recommended ment al health counseling, consistent with his stated diagnosis that Plaintiff suffered from polysubstance abuse. 15 In addition, Sikes had other medical staff members monitor Pl aintiff’s behavior and symptoms, and he took affirmative steps to prevent Plaintiff from harming herself and others. Such actions readily distinguish Sikes’s care from the deliberate indifference in Steele and
Greason

. 16 2. Expert Testimony Lacking direct or circumstantial factual evidence to establish or to allow a jury to infer Sikes’s knowledge, Plaintiff attempts to create a factual issue regarding Sikes’s mental intent by submitting opinion testimony by medical experts. In affidavits and depositions, Plaintiff’s experts testify that given Plaintiff’s prior hospitalizations and medication and her symptoms and behavior, Sikes should have known that Plaintiff had bipolar disorder and needed medicati on and that Sikes’s treatment was grossly inadequate. In response, Defendants present expert testimony opining that Defendants’ medical care fully complied withthe applicable standards of care and that reasonable17 Indeed, another issue before the Steele Court was whether the district court had erred in refusing to appoint an expert witness to a ssist the plaintiff. 87 F.3d at 1271. The Court remanded for the district court to reconsider a ppointing an expert, noting that “the appropriate standard of psychiatric care” was at issue and that “[e]xpert opinion on that issue and its 35 35 mental health professionals could have reached the same conclusions Defendants reached and taken the same actions Defendants took. Plaintiff’s experts’ opinion testimony directly contradicts th at of Defendants’ experts. The question becomes whether the opini on testimony by Plaintiff’s experts here creates a jury issue regarding Defendants’ subjective mental intent required by Farmer

. More specifically, the issue is this: since th e facts and circumstances of this case do not allow an inference that Sikes not only shoul d have perceived the risk but also actually did perceive it, does the opinion testimony by Plaintiff’s medical experts based on those same facts and circumstances provide the missing Farmer link? The answer is

no. We begin by examining our precedent fo r guidance. This circuit has not discussed directly the precise role of expert testimony in a post-Farmer decision turning on the subjective mental intent of medical professionals sued for deliberate indifference to an inmate’s serious psyc hiatric medical needs. Neither Steele nor Greasonrelies on opinion testimony by medical experts as evidence that the psychiatrist knew his care was grossly inadequate. In Steele the plaintiff presented no expert testimony at all, 17 and in Greasonthis Court relied on expert testimony only inapplication here obviously might be important to the finder of fact.” Id. ; see also Young v. City of Augusta , 59 F.3d 1160, 1169-70 (11th Cir. 1995) (upholdi ng the district court’s decision not to appoint an expert to assist plaintiff Young b ecause “[t]he presence of a genuine issue of fact with respect to deliberate indifference to Young’s medical needs is apparent from the face of the record” without any expert testimony).

18 Greasonrelies on expert testimony in listing what the defendant psychiatrist would have known had he reviewed the inmate’s file before discontinuing medication: there was testimony by a psychiatrist “that Greason possessed a great number of the characteristics associated with a high suicide risk.” 891 F.2d at 835 n.11. It also relies on expert testimony “that Greason received grossly inadequate care,” and it reaffirms a past case’s holding that “the conflict among the experts concerning the propriety of the psychiatrist’s professional judgment calls [must] be resolved by the jury.” Greason , 891 F.2d at 835.

19 See footnote 13 supra

. 36 36 addressing the objective prong of deliberate indifference. 18 Instead, the egregious facts and circumstances in those cases created the requisite factual issue of deliberate indifference or wanton conduct. The parties rely heavily on this Court’s tr eatment of expert affidavits in Dolihite v. Maughon , 74 F.3d 1027 (11th Cir. 1996). However, like Greason , Dolihite considers expert medical affidavits only in relation to the objective inquiry of qualified immunity–whether a reasonable medical prof essional in the defendants’ position would have known that the defendant s’ actions violated the juvenile’s constitutional rights. 19
Dolihite acknowledges that in the unique context of a claim of deliberate indifference to medical needs, expert testimony is relevant to ascertaining the applicability of qualified immunity: Our circuit has indicated that the te stimony of medical experts can aid the court in determining whether qualifie d immunity is appropriate where37 37 allegations hinge upon the appropria teness of the actions of medical professionals, including mental health professionals. Id. at 1046. Dolihite does not address the role of expert testimony in determining whether a plaintiff has sufficient evidence of the subjective mental intent required for a jury finding of deliberate indifferen ce to serious medical needs under Farmer

. Indeed, the majority opinion in Dolihite does not even cite Farmer . Moreover, Dolihite ’s explanation for considering expert testimony is particular to the objective qualified immunity inquiry: Such expert medical testimony, maki ng reference to specific deficiencies in a defendant’s treatment and sp ecific medically accepted standards might, in conjunction with the specific facts of a case, persuade a court that the medical defendant’s actions in the case were clearly as great a departure from appropriate medical standards as previous departures found unconstitutional in prior cases–i.e ., might persuade a court that a reasonable professional in defendant’s shoes would have known that his challenged actions (or inaction) violated plaintiff’s constitutional rights. Id. at 1046. Thus, Dolihite ’s consideration of expert testimony in applying qualified immunity’s objective standard does not answ er our question about the role of expert opinion testimony when applying Farmer ’s subjective-intent requirement. In two other conditions-of-confinement cases since Farmer , the plaintiffs failed to create triable issues regarding the de fendants’ subjective mental intent. Each opinion lends support to our ultimate c onclusion regarding e xpert testimony, but admittedly neither is squarely on poi nt here. In Cottrell v. Caldwell , 85 F.3d 148020 See footnote 12 supra

. 38 38 (11th Cir. 1996), this Court held that the plaintiff’s expert affidavit regarding what “was well known by police” was insufficient to create a jury issue regarding Farmer ’s subjective component. Id. at 1491. The Court explai ned that “such a conclusory statement about police in general is not evidence about the mental state of these defendant officers in particular.” Id. Although helpful guidan ce on the role of expert testimony, Cottrell does not fully answer the question here for two reasons. First, Cottrell involves expert affidavits about po lice officers’ positioning and restraining arrestees in police cars, as opposed to e xpert medical testimony. Also, Cottrell appears to rely in part on the conc lusory nature of the affidavits, and not all the testimony Plaintiff presents in this case is so conclusory. Similarly, in Adams v. Poag , 61 F.3d 1537, 1543-48 (11th Cir. 1995), this Court examined the plaintiff’s expert testimony and found it failed to create a triable issue regarding the defendants’ subjective inte nt. However, as noted above, Adams is framed in terms of qualified imm unity and does not cite Farmer

. 20 Moreover, Adams , too, seems to rest on particular deficien cies in the wording of the affidavits at issue–deficiencies that are present in a greatdeal of, but not all, the testimony Plaintiff relies on in this case.39 39 Lastly, in Hale v. Tallapoosa County , 50 F.3d 1579 (11th Cir. 1995), a postFarmer inmate-on-inmate violence case, we considered experts’ opinions, but only where other factual evidence showed th e defendant sheriff’s actual knowledge. Considering all the evidence, we found a tr iable issue as to whether the defendant possessed the subjective mental intent required by Farmer . Id. at 1583. Importantly, however, our finding of a factual issue did not rest on expert testimony alone. Although we noted the expert’s testimony that “given the conditions in the months preceding [the attack], it was plainly fore seeable to a reasonable law enforcement official that a violent attack was likely to occur,” we also stresse d the defendant’s own admission “that he knew that inmate-on- inmate violence was occurring on a regular basis” and “that he knew the violence some times resulted in injuries requiring medical treatment.” Id. Lacking a controlling application of Farmer ’s standard, we turn to Farmer itself.
In Farmer , the Supreme Court made clear thatthe subjective mental intent prong requires that the official actually know of a substantial risk of serious harm to the inmate’s health and then di sregard that risk. Farmer , 511 U.S. at 837. An “official’s failure to alleviate a significant risk thathe should have perceived but did not, while no cause for commendation, cannot . . . be condemned as the infliction of punishment.”40 40 Id. at 838. Under Farmer , proof that the defendant should have perceived the risk but did not is insufficient. Id. at 838. Farmer also explains: When instructing juries in deliberat e indifference cases with such issues of proof, courts should be careful to ensure that the requirement of subjective culpability is not lost. It is not enough merely to find that a reasonable person would have known, or that the defendant should have known, and juries should be instructed accordingly. Id. at 843 n.8. Instead, the plaintiff must submit evidence that the medical professional defendant actually was aware of the significan t risk of serious harm but deliberately proceeded with grossly inad equate treatment anyway. The issue of subjective mental intent under Farmeris different from whether Sikes’s medical treatment was negligent or gr ossly inadequate. To decide the issue of subjective mental intent under Farmer , a jury would inquire (1) whether Sikes was aware of facts about Plaintiff from which he could draw the inference that his present course of treatment presented a substantial risk of serious harm to Plaintiff and (2) whether he actually drew that inference but persisted in the course of treatment anyway. There is no direct or circumstan tial evidence in this record from which the jury could infer Sikes’s actual knowledge, and Plaintiff’s experts’ testimony does not provide the missing link under Farmer –at least under the facts and circumstances of this case. Indeed, allowing expert tes timony that Sikes should or would have known to raise a jury issue as to whether he actually knew effectively would nullify Farmer’s21 While we do not rely on deficiencies in the wording of the expert affidavits, we do note a few of their shortcomings. For example, the experts’ testimony contains many conclusory statements that Defendants were deliberately indi fferent that do not govern our assessment of the evidence. See Dolihite , 74 F.3d at 1046-47 & n.33 (explaining that “an expert opinion which is merely conclusory, even if couched in the language of the relevant legal standard, will be of little assistance to a court”); Cottrell , 85 F.3d at 1491 (“[A] conclusory statement about police in general is not evidence about the mental state of these defendant officers in particular.”); Rogers v. Evans , 792 F.2d 1052, 1062 n.9 (11th Cir. 1986) (holding that an affidavit “phrased in conclusory terms” was “defective to create a factual dispute”). In addition, some of the affidavits rest on false factual predicates. For instance, the opinion of James S. Cheatham, M.D., seems to rely in part on the assumption that Plaintiff had been diagnosed as suffering for bipolar disorder prior to entering GWCI. Neither the Cobb County jail records nor the other medical records in evidence contain a prior diagnosis of bipolar disorder. Also, of the expert affidavits Plaintiff pres ents, the principal affidavit that opines about what medical professionals would know is by John R. Paddock, who has a Ph.D. in psychology. Dr. Paddock reviews the behavior Defendants observed and the treatment they implemented and states, “Any person with professional credentials in the area of mental illness or the treatment of mental or emotional disorders would know thatwhat the Defendants were doing was grossly improper in design, approach, and implementation.” In certain areas, such as prescribing medicine, the training of psychologists and psychi atrists is not equivalent; thus, Dr. Paddock is not a competent expert to testify to what a psychiatrist like Sikes would know about the need to prescribe medicine. Finally, there is the opinion statement of Kenneth I. Robbins, M.D. that Sikes’s own testimony “demonstrates he knew his behavior was improper.” However, Sikes’s testimony itself either does or does not prove knowledge. Dr. Robbins’s opinion about what Sikes’s testimony shows is not probative. Moreover, Sikes’s testimony, that Dr. Robbins refers to here, does not demonstrate that Sikes knew his behavior was improper. What Dr. Robbins is referring to here is that Sikes testified restraints were only to be used in limited situations and that Sikes left his patient in restraints over a weekend. Dr. Robbins concludes from Sikes’s testimony about the limited use of restraints that Sikes knew leaving Plaintiff in restraints over a weekend was improper. However, Dr. Robbins fails to note the undisputed evidence that other psychiatrists were on call that weekend, that they were available to answer correctional officers’ 41 41 requirement of subjective mental intent. The deficiency of the expert testimony here arises not necessarily from the specific wording of the experts’ testimony–although some of Plaintiff’s affidavits are lacking in many respects 21 –but from the inherentquestions, and that they were called upon every twenty-four hours to reassess the continued need for restraints. Thus, Sikes’s testimony does not create a factual issue regarding Sikes’s knowledge that his care was grossly inadequate –nor does Dr. Robbins’s opinion about Sikes’s testimony.

22 We located one post-Farmer circuit court decision squarely addressing whether expert medical testimony can create a factual issue about subject mental intent in cases involving deliberate indifference to serious medical needs. In McKee v. Turner , No. 96-3446 (6th Cir. Aug. 25, 1997), the Sixth Circuit held the defendant psychiatrist was entitled to summary judgment because there was no evidence showing that the psychiatrist had acted with deliberate indifference. The expert’s affidavit stated th at the defendant psychiatrist had departed from accepted standards of medical care and that the risk of suicide “must have been obvious” to the defendant psychiatrist. The Sixth Circuit held that this affidavit was insufficient to support a finding of deliberate indifference, stressing that under Farmer , “the official’s conduct is judged by what he actually knew, not by what a reas onable person in his shoes would have known.” The Sixth Circuit concluded: The issue here is not whether Dr. Morcos committed medical malpractice, but rather whether Dr. Morcos had knowledge or facts about [Plaintiff] from which he could draw the inference that his present course of treatment presented a substantial risk of serious harm to [Plaintiff], and that he actually drew that inference, but persisted in the course of treatment anyway. There is nothing in the record demonstrating this. 124 F.3d 198; see also Williams v. Mehra , 135 F.3d 1105 (6th Cir.), vacated and set for reh’g en banc , 144 F.3d 428 (6th Cir. 1998). 42 42 opinion nature of expert te stimony about what a person should or would have known. The particular conflicting expert testimony here demonstrates only that there is a difference of opinion among professionals about what is accepted practice within the psychiatric community and what a doctor s hould or would know. Plaintiff’s experts’ testimony here at best allows an infere nce by the jury that a doctor should have perceived the risk of serious harm but not an inference that the doctor actually did perceive the risk and persisted inhis course of treatment anyway. 2223 See also Lancaster v. Monroe County , 116 F.3d 1419, 1426-29 (11th Cir. 1997) (finding defendants’ own testimony regarding their knowledge and other evidence that the defendants were personally warned of the detainee’s condition created triable issues regarding defendants’ subjective mental intent without any expert testimony). 43 43 Of course, rarely if ever will a defe ndant medical professional admit that he knew his course of treatment was grossly in adequate but proceeded with that treatment anyway. Therefore plaintiffs necessarily must use circum stantial evidence to establish subjective mental intent. See Farmer , 511 U.S. at 842; Lancaster v. Monroe County , 116 F.3d 1419, 1426 (11th Cir. 1997); Steele , 87 F.3d at 1269. But expert opinion testimony is not essentia l to that task. For example, in both Steele and Greason , the plaintiffs created triable issues regarding the defendants’ knowledge without any expert opinion te stimony by presenting evidence of the particular facts and circumstances in those cases. 23 As noted above, the doctor in Steele stopped Steele’s medication after a “le ss than one minute” meeting and without reviewing medical records. More im portantly, the doctor proceeded with no medication in the face of warnings from the prior institution that the plaintiff was a suicide risk, had tried suicide twice, and needed psychotropic medication. The doctor’s conduct was similar in Greason : he saw Greason for a few minutes, promptly concluded that Greason’s condition had stabilized, and discontinued Greason’s medications without reviewing the clinical file or assessing Greason’s mental status to determine his potential for suicide. The lette rs in the clinical file showed Greason was24 On December 7, 1998, Moore’s counsel filed notice that Moore had died on November 22, 1998. 44 44 a schizophrenic, had suicidal tendencies, and needed me dication. In both Greasonand Steele , this Court relied on facts and circumstances that made the risk of grossly inadequate care and suicide so obvious that a jury could infer th e defendants’ actual knowledge. In contrast, here there was no prior diagnosis of bipolar disorder, and the jail officials advised that they did not consider Plaintiff’s suicide threats to be serious and that they perceived Plaintiff’s aberrant behavior as an attempt to manipulate officials. Because Plaintiff has not presented suffici ent direct or circumstantial evidence to create a factual issue regarding Sikes’s subjective mental intent and the experts’ opinion testimony here does not provide the missing link, we affirm the magistratejudge’s decision to grant Sikes summary judgment on Plaintiff’s deliberateindifference claim.
E. Defendant Moore Defendant Moore was a licensed psychol ogist who worked one day a week at
GWCI. 24 Unlike Sikes, Moore could not prescribe medication. Moreover, because Moore worked at GWCI only one day a week, his duties and responsibilities were25 Some of the expert testimony about Moore’s care seems to rest on the erroneous assumption that Moore’s knowledge about Plainti ff was commensurate with Sikes’s. However, as with Sikes, we do not rely on particular deficiencies in the affidavits. 45 45 decided week by week on an as-needed basi s. Moore saw Plain tiff six times between August and October 1991. His last contactwith Plaintiff was on October 24, 1991. Plaintiff has failed to present sufficien t evidence for a reasonable jury to find Moore knew that Plaintiff had bipolar disorder or that his treatment was grossly inadequate. Moore diagnosed Plaintiff as having a personality disorder, as opposed to a mental illness, and Plaintiff has presented no evidence that Moore knew his diagnosis was incorrect. Plaintiff’s primary contention is that Moore should have performed psychological tests even though Sikes did not order them. Again, Plaintiff presents expert testimony about Moore’s care, wh ich might establish Moore breached the standard of care and was negligent but does not support a finding that Moore knew Plaintiff was misdiagnosed and needed medication or knew his care was otherwise inadequate. 25 Without evidence of Moore’s subjec tive intent, Plaintiff’s deliberateindifference claim cannot succeed.
F. Defendant Ford Defendant Ford is a mental health counselor, untrained in diagnosing mental illness and unauthorized to prescribe medicati on. Plaintiff was assigned to Ford for46 46 counseling during most of the eight-month pe riod in question. Ford had almost daily contact with Plaintiff. Plaintiff focuses on two alle ged deficiencies in the car e Ford provided. First, Plaintiff points to an October 1991 memorandum Ford wrote to prison security personnel instructing that they impose ma ximum disciplinary penalties for Plaintiff’s infractions of prison rules. The memorandum states that Plaintiff had received seventeen prior disciplinary reports, that Pl aintiff had been evaluated several times by Drs. Moore and Sikes, that Plaintiff “does not currently have an Ax is I diagnosis,” and that therefore “[t]he current treatment goal for Ms. Campbell as recommended by Dr. Sikes and the mental health staff is behavior modification.” There is no evidence to support a jury finding that by writing the security memorandum Ford was deliberately indifferent to Plaintiff’s serious medical needs. First, the memorandum also states that “[m] edical staff will be responsible for ensuring that medical needs are met according to po licy.” Second, Plaintiff has presented no evidence that Ford knew Plaintiff suffered from bipolar disorder–much less that Ford knew Plaintiff’s self-destructive and defian t behavior stemmed from bipolar disorder. Moreover, Ford wrote this memorandum at Sikes’s direction, acting on the express instructions of a medical doctor who was tr ained in diagnosis of mental illness, had26 According to Plaintiff, the medical doctor’s order approving the four-point restraints used on this occasion was signed almost two months later on March 24, 1991. 47 47 diagnosed Plaintiff with polysubstance abuse and not bipolar disorder, and had recommended behavior modification treatment as opposed to medication. Second, Plaintiff faults Ford for the ove rnight “delay in treatment” once it had been determined that Plaintiff needed to go to Central for further evaluation. It is undisputed that on the night of January 29, Ford knew it had been determined that Plaintiff should be sent to Central. It is al so undisputed that officials secured Plaintiff in four-point restraints overnight and sent her to Central the next morning. Plaintiff alleges that it was Ford’s decision to delay th e transfer and that Ford decided to apply four-point restraints without a prior order from a medical doctor. 26 Again, however, Plaintiff has presented no evidence that Ford knew that Plaintiff had bipolar disorder or that such overnight delay amounted to grossly inadequate care. Dr. Paddock’s affidavit purports to support a finding that Ford “had to know” the care Plaintiff received was grossly inadequate: Defendant Ford was in a position and exercising responsibility in which she would have had to know thatfurther and additional mental health/psychological evaluation and assessment of Ms. Plaintiff were required by her and consistent with the competencies of other members of the treatment team (e.g., licensed psychologists and psychiatric physicians), and that the acts undertaken were grossly deficient.27 Plaintiff’s supervisory liability claim against Sikes fails for the same reason. 48 48 As discussed regarding Sikes, this expert affidavit does not suffice to support a finding that Ford knew her care was gro ssly inadequate but persisted inthat treatment. At best, it might support a finding that Ford’s care was grossly inadequate or a finding that Ford should have known or perceived–or “had to know”–her care was grossly inadequate. However, as explained above, “[t]here is no liability for ‘an official’s failure to alleviate a significant risk that he should have perceived but did not . . . .’” Cottrell v. Caldwell , 85 F.3d 1480, 1491 (11th Cir. 1996) (citing Farmer , 511 U.S. at 838).
G. Defendant Gavin Plaintiff acknowledges that Defendant Gavin, the GWCI warden, was not employed as a mental health professional. Plaintiff claims only that Gavin was deliberately indifferent in supervising others who were deliberately indifferent to her serious medical needs. By its own terms, Plaintiff’s claim against Gavin cannot succeed without evidence of an underlying constitutional violation by one of the mental health professionals. As explained above, the record contains no such evidence. Thus, Gavin is necessarily entitled to summary judgment on this claim. 27
VI. EXCESSIVE FORCE49 49 Plaintiff also claims that even if Defendants’ actions did not amount to deliberate indifference to her serious medical needs, their use of restraints constituted excessive force. A. Proof Required that Force Used Maliciously and Sadistically to Cause Harm The Eighth Amendment’s proscription of cruel and unusual punishments also governs prison officials’ use of for ce against convicted inmates. See Whitley v. Albers , 475 U.S. 312, 327 (1986) (holding that “the Due Process Clause affords [convicted prisoners] no greater protec tion than does the Cruel and Unusual Punishments Clause”). To establish an Eighth Amendment claim for excessive force, however, Plaintiff must meet an intent requirement more stringent than Farmer ’s deliberate-indifference standard: she must prove that “force was applied . . . maliciously and sadistically for the very purpose of causing harm.” Whitley , 475 U.S. at 320-21 (quoting Johnson v. Glick , 481 F.2d 1028, 1033 (2d Cir. 1973)); see also Hudson v. McMillian , 503 U.S. 1, 6-7 (1992). Discussing this heightened specifi c-intent requirement in Whitley , the Supreme Court reiterated that force does not violate the Eighth Am endment merely because it is unreasonable or unnecessary: “The inflicti on of pain in the course of a prison security measure . . . does not amount to cruel and unusual punishment simply because it may appear in retrospect that the degree of force authorized or applied for security50 50 purposes was unreasonable, and hence unnecessary in the strict sense.” 475 U.S. at 319. Reviewing the force used to quell a prison riot in Whitley , the Court explained that “whether the measure taken inflicte d unnecessary and wanton pain and suffering ultimately turns on ‘whether force was app lied in a good faith effo rt to maintain or restore discipline or maliciously and sadi stically for the very purpose of causing harm.’” Id. at 320-21 (quoting Johnson , 481 F.2d at 1033). Subsequently, in Hudson v. McMillian , 503 U.S. 1 (1992), the Supreme Court extended Whitley ’s holding outside the prison-riotcontext and applied the same heightened intent requirement to force usedas a prophylactic, prev entive measure. See Whitley , 475 U.S. at 322 (acknowledging the distinction). The Hudson Court held that “whenever prison officials stand accused of us ing excessive physical force in violation of the Cruel and Unusual Punishments Clause, the core judicial inquiry is that set out in Whitley : whether force was applied in a good-fa ith effort to maintain or restore discipline, or maliciously and sadi stically to cause harm.” Id. at 6-7. The Court reasoned that even absent the exigency present during a riot-like disturbance, “‘“[p]rison administrators . . . should be accorded wide-ranging deference in the adoption and execution of polic ies and practices that in their judgment are needed to preserve internal order and discipline and to maintain institutional security.”’” Hudson , 503 U.S. at 7 (quoting Whitley , 475 U.S. at 321-22 (quoting Bell v. Wolfish , 441 U.S.51 51 520, 547 (1979))). Thus, Hudson dictates that Whitley ’s standard–force applied maliciously and sadistically to cause harm–a pplies to all claims that prison officials used excessive force against convicted prisoners. In addition to defining the mental state required, Hudsonand Whitleyoutline five distinct factors relevant to ascertain ing whether force was used “maliciously and sadistically for the very purpose of causing harm”: (1) “the extent of injury”; (2) “the need for application of force”; (3) “the relationship between that need and the amount of force used”; (4) “any efforts made to temp er the severity of a forceful response”; and (5) “the extent of the threat to the safety of staff and inmates, as reasonably perceived by the responsible officials on the basis of facts known to them.” Whitley , 475 U.S. at 321; see also Hudson , 503 U.S. at 7. Whitley also narrows the precise inquiry applicable when deciding whether officials are entitled to judgment as a matter of law: courts must determine whether th e evidence goes beyond a mere dispute over the reasonableness of a particularuse of force or the existence of arguably superior alternatives. Unless it appears that the evidence, viewed in the light most favorable to the plaintiff, will support a reliable inference of wantonness inthe infliction of painunder the standard we have described, the case should not go to the jury. Whitley , 475 U.S. at 322 (emphasis added). B. Eleventh Circuit Applications52 52 Plaintiff’s excessive-force claim focuses on restraints Defendants used while she was in isolation. Thus, we review prio r decisions of this Court applying Whitleyto uses of restraints and isolation. Affirming summary judgment in Williams v. Burton , 943 F.2d 1572 (11th Cir. 1991), this Court held that the officials’ us ing four-point restraints and a gag was not excessive force. Officials placed Williams infour-point restraints , with gauze and tape over his mouth, for twenty-ei ght and one-half hours. Id. at 1574. There were only brief intervals for eating, physical exercise, and toilet use. Id. Noting that Williams had threatened to kill officials, spat on them, and thrown bodily fluids at them, this Court explained that the four-point restrain ts and gag were not ex cessive force but were used to prevent Williams from harming himself or officials: [t]he four-point restraints were used to reduce or eliminate Williams’ ability to inflict physical harm agains t either himself or the correction officers. The restraints were not us ed for the purpose of inflicting pain. The gauze padding and tape were used to prevent Williams from encouraging further unrest among the other inmates in the segregation unit, as well as to protect the officers from his continuing spital assault. Id. at 1575. Also important to the Williams decision were the observations (1) that although the inmate “experienced some discom fort because of his restraint, no actual injury was inflicted” id. ; and (2) that “constant monitoring and examinations by medical personnel” were adequate to sa feguard the inmate’s well-being. Id.53 53 Williams stresses that courts s hould afford great deference to prison officials regarding the use of restraints as a pr ophylactic or preventive measure, stating: How long restraint may be continued calls for the exercise of good judgment on the part of prison officials. Once it is established that the force was applied in a good faith e ffort to maintain discipline and not maliciously or sadistically for the purpose of causing harm, the courts give great deference to the actions of prison officials in applying prophylactic or preventive measures intended to reduce the incidence of riots and other breaches of prison discipline. Id. at 1576 (internal citations omitted). This Court also found the officials’ “continuous observation and management of Williams during his restraint” showed their good faith, and we concurred with th e district court’s holding that “Williams’ history of persistent disobedience and the pot ential for a disturban ce in the segregation unit justified the continued use of the restraints and gag until the officers were reasonably assured that the situation had abated.” Id. Similarly, in Sims v. Mashburn , 25 F.3d 980 (11th Cir. 1994), this Court upheld the officials’ use of a stripped cell for twenty-nine hours and reversed the district court’s grant of judgment for the inmate. The inmate in Sims hung various items over the window to his cell, preventing prison officials from observing his behavior; he placed a towel in the toilet, which officer s took as an implicit threat to flood the segregation unit; and he threatened that if officials entered his cell, “I’ll buck; you’ll have to kill me.” Id. at 981. On that basis, offici als stripped his cell and removed all54 54 clothing except his undershorts, and they di sconnected the water to his toilet. Id. at 981-82. In determining whether the officials ha d used good faith or acted “maliciously and sadistically to cause harm,” this Cour t observed that the officers had followed the prison’s operating procedures for stripping cells, which required, among other things, documenting the incident and checking on the inmate’s status every fifteen minutes. Id. at 985-86. Again, we emphasized that co mpliance with an established prison policy evidences an official’s good faith, particularly when, as in Sims , “[t]he policy itself reflects a well-developed and planned procedure.” Id. at 986. In the field of prison discipline, “prison officials, not judges, are experts.” Id. C. Application To This Case Plaintiff focuses on the instances in whic h officials used the “L” shape restraint in addition to the straightjack et. The record reflects that officials used the “L” shape restraint at least five different times fo r periods of twenty-seven hours on September 18 to 19, one hour and twenty-five minutes on September 22, five hours on October 12 to 13, sixteen hours on October 23 to 24, and sixty-six hours and forty minutes on October 25 to 28. As explained above, Plaintiff’s excessi ve-force claim depends on whether these periods of restraint were in stituted “maliciously and sadi stically for the very purpose55 55 of causing harm.” Precedent dictates that this determination be guided by the five Hudson/Whitley factors outlined above, by deference to prison officials’ punitive judgments, and by this Court’s previous hol dings that compliance with prison policies evidences officials’ good faith. For severa l reasons, such considerations convince us that the record here does notcreate a factual issue regarding malicious or sadistic intent. First, the urgent need for force was readily apparent each time the “L” shape restraint was applied; the undisputed facts show Plaintiff posed a serious threat to herself and to others. Plaintiff not only told officials that she was considering suicide but also actually took steps toward harming herself on more than one occasion. When the “L” shape restraint was applied initia lly in September 1991, officials found her standing on the bed with a sheet around her n eck. As noted above, on other occasions, she thrashed about her cell, climbed up on the sink, ripped her sheets to shreds, beat on and dismantled the overhead light, and attempted to obtai n sharp objects. Plaintiff also bit and scratched prison officials, and she repeatedly threatened to “hurt someone.” Some of Plaintiff’s actions posed a security risk as well. She regularly threatened to flood the toilet, and she often started fires in her cell, burning such items as her food tray, her Bible, and her clothing. One clothing fire mandated evacuation of her entire cellblock.28 Plaintiff asserts that there was one instance in which she urinated on herself while in restraints and the situation was not discovered for some hours. 56 56 Moreover, lesser restraints were ineffective in curbing Plaintiff’s dangerous behavior. Plaintiff freed herself from straightjackets on multiple occasions. In addition, on one occasion when officials used only a straightjacket, Plaintiff began banging her head and kicking. Although resulting in physical discomfort and emotional pain, the restraints undisputedly caused Plaintiff no physical injury. More importantly, the officers carefully monitored Plaintiff’s physical condition while she was restrained. They checked Plaintiff’s circulation each time they applied the “L” shape method of restraint, and security officers checked Pl aintiff every fifteen minutes while she was restrained. There were also regular checks by medical staff, with a nurse evaluating Plaintiff’s condition every few hours and a doctor reassessing the need for restraints every twenty-four hours. Additionally, the severity of the restra int was tempered somewhat by attention to Plaintiff’s basic physical needs. During periods of restraint, Plaintiff was given “toileting” on request, 28 offered meals at regular inte rvals, and sometimes given a mattress rather than being made to lie on the floor.29 Plaintiff entered in the record before the magistrate judge a videotape of several “L” shape incidents, and that tape is part of the record on appeal as well. 57 57 Also evidencing the officials’ good fa ith is their compliance with prison procedures for using restraints. GWCI policies provide for ex tensive documentation and monitoring when restraints are used , and Defendants met and exceeded those requirements. For example, in addition to completing the required written documentation, Defendant s videotaped some of the instances in which they used the “L” shape restraint. 29 In addition, on at least two different occasions, Sikes declined to approve restraints when other officials requested them. Each time, Sikes instructed the requesting officials that restraints should not be applied when Plaintiff did not pose a threat to her own safety. Such decisionm aking by Sikes hardly betrays a malicious or sadistic motive. Plaintiff provides no viable reason to depart from the conclusion dictated by these considerations. Her main contention is that four-point restraints would have been equally effective and less dehumanizing than the “L” shape. In addition, she points to a deputy prison commissioner’s testimony that he was shocked to hear that prisoners were being “hog-tied.” Howe ver, such evidence raises “a mere dispute over the reasonableness of a particular use of fo rce or the existence of arguably superior30 It is far from clear in the case law th at officials’ violating prison policy would necessarily establish the requisite subjective mental intent. In this case, however, because there is insufficient evidence to support a finding that prison policies were violated, we need not address whether a violation of prison policies is per se malicious and sadistic.

31 We refer to the policies in effect when the challenged instances of restraint occurred. There is some indication in the record that since that time, the policies may have been amended to proscribe “hog-tying.” 58 58 alternatives,” Whitley , 475 U.S. at 322, and would not suffice to support a jury finding that the officials restrained Plaintiff in this manner “maliciously and sadistically for the very purpose of causing harm.” Id. at 320-21. There is also no showing that the “L ” shape method of restraint used here violated prison policies. 30 Both GDOC and GWCI policie s clearly allowed restraints to be used to curb dangerous behavior, and neither policy forbade this particular method of restraint. GDOC operating proce dures merely authorized restraints “to prevent the inmate from hurting himself or others” and defined “hard restraints” versus “soft restraints.” GDOC Standard Oper ating Procedure No. VC01-0014 (Revised Oct. 1, 1989). 31 Similarly, GWCI policy authorized restraints as “a temporary means of controlling an inmate’s destructive behavior toward herself and others.” GWCI Policy Statement No. 801.1 (activated Nov. 1, 1989; revised June 13, 1991). GWCI policy also examined the costs and benefits of se veral different methods of restraint, noting that “[t]he following comments should be reviewed and considered in making a decision as to which devices to use when restraint is necessary.” Id. The “L” shape59 59 method used here was not expressly listed, but GWCI policy expr essly provided in a separate subsection that a physician might “also consider other options as to the method of restraint most likely to be appropriate.” Id. Plaintiff argues that the absence of “hog-tying” from the lists of possible restraint methods meant the “L” shape method used here was forbidden. In support of that contention, she offers the tes timony of a deputy prison commissioner who interpreted the state operating procedures to ban “hog-tying.” However, the deputy commissioner’s testimony is insufficient to creat e a triable issue in the face of the clear and unambiguous language of the policies them selves, which did not ban or in any way proscribe this method of restraint but inst ead expressly permitted doctors to consider using other methods of restraint.
VII. CONCLUSION Because we find insufficient evidence to s upport a jury’s finding that any of the Defendants possessed the subjective mental intent required to support Plaintiff’s deliberate-indifference and excessive-force claims, the magistrate judge’s grant of summary judgment for Defendants Sikes, Moore, Gavin, and Ford is AFFIRMED.