A sentence to prision invovles much more than simple incarceration and its attendant withdrawal of freedom of movement. Indeed, as recent developments indicate, a sentence to confinement in most penal institutions involves a life and death struggle to avoid at tacks, rapes, and brutality from fellow inmates as well as from correctional authorities. ... The National Advisory Commission on Criminal Justice Standards and Goals recognized the problem in recommending a comprehensive model standard which would require correctional officials, the only state authority "in a position to protect inmates, to take protective measures on the inmates' behalf, and to compensate those it failed to protect. These standards are, however, only recommendations to legislatures and correctional agencies, and although they embody the most current correctional philosophies, they are binding on no jurisdictions.
Robert Plotkin, Surviving Justice: Prisoners' Rights to Be Free from Physical Assault, 23 Clev. St. L. Rev. 387 (1974)