showing that solitary confinement constitutes cruel and unusual punishment has proven difficult for inmates and their attorneys. the supreme court requires ‘extreme deprivations’ in order to have merits for a ‘conditions-of-confinement claim’ and courts have also held that inmates are only protected against “certain kinds of extreme deprivations” by the eighth amendment. in ‘‘farmer v. brennan’’, the supreme court set two requirements that must be fulfilled in order to challenge solitary confinement as “cruel and unusual”. first, prisoners must show that a “substantial risk of serious harm to inmates” and second, that the prison officials were “deliberately indifferent” to such risk. to prove a prison official's “deliberate indifference,” the prisoner must “show evidence that the official was ‘actually’ aware of a prisoner's serious need and chose to ignore it”. since the psychological impact of solitary confinement is not believed to be “objectively” cruel and unusual within the u.s. legal system, and because it is difficult to establish that prison officials are “indifferent” to prisoner health and safety, inmates and attorneys alleging these two requirements have faced limited success.