During the past decade, most gang-related civil cases in Federal courts have concerned inmates' claims that: (1) prison or jail officials failed to protect them from gang members; (2) their classification or placement based on their affiliation with gangs was unconstitutional; (3) institutional grooming policies, partially implemented as an anti-gang measure, were unconstitutional; and (4) prison or jail officials improperly prohibited written or audio materials believed to foster development of prison gangs. The article claims it is very difficult for inmates to claim violations of their Eighth Amendment rights for failure to protect them from violence in prison or jail. To be held liable, defendants must have specific information regarding the anticipated violence. Claims under the Fifth and Fourteenth Amendments based on gang members' classification or placement in administrative detention rarely succeed because there is no "atypical deprivation" under Sandin v. Connor. References, note