Supreme Court Denies Qualified Immunity, Finding that Law Is Clear Inmates Require Clean Cells
This case law update was written by Michael J. Sgarlat, an attorney at the law firm of Shaw Bransford & Roth, where he has practiced federal personnel and employment law since 2015. Mr. Sgarlat works with federal employees to respond to proposed disciplinary and adverse actions, and has experience litigating cases before the U.S. Merit Systems Protection Board.
Trent Taylor is an inmate at the Texas Department of Criminal Justice. For six days in September 2013, Taylor claimed that correctional officers confined him in two different unsanitary cells. In the first, the floor, the ceiling, the window, the walls, and even the water faucet were covered in feces. Taylor did not eat or drink for four days because he feared that he would consume contaminated products.
In the second, which Taylor described as a “frigidly cold cell,” the drain to dispose of bodily wastes was clogged. Taylor held his bladder for over 24 hours until his body gave in and he relieved himself. When he did, the drain overflowed and sewage spilled across the floor. Taylor, who was confined without clothing, was forced to sleep naked in raw sewage.
Taylor sued the correctional officers at the John T. Montford Unit of the Texas Department of Criminal Justice under 42 U.S.C. § 1983 for violating his Eighth Amendment rights, and its prohibition on cruel and unusual punishment. The district court denied the correctional officers’ motion to dismiss Taylor’s claims as insufficiently plead, but later, granted summary judgment to the correctional officers on. The district court found that the cell conditions did not violate the Eighth Amendment’s prohibition against cruel and unusual punishment because Taylor was “exposed to the alleged conditions for only a matter of days,” and the correctional officers used “a towel to wipe the sewage from the floor.”
Taylor appealed the district court’s decision to the Court of Appeals for the Fifth Circuit. On appeal, the court of appeals held that the conditions of confinement at issue did violate the Eighth Amendment’s prohibition on cruel and unusual punishment. However, the court of appeals found that “[t]he law wasn’t clearly established” that “prisoners couldn’t be housed in cells teeming with human waste” “for only six days,” and concluded that the correctional officers responsible for Taylor’s confinement did not have “fair warning” their conduct was unconstitutional.
On April 24, 2020, Taylor petitioned for writ of certiorari. On November 2, 2020, the Supreme Court granted Taylor’s petition, and issued its opinion without oral argument. The Supreme Court found that the Fifth Circuit erred in granting the officers qualified immunity in this case. Specifically, the Court disagreed with the court of appeals’ finding that the law was not clearly established that prisoners cannot be housed in such inhumane conditions.
The Court stated that “no reasonable correctional officer could have concluded that, under the extreme circumstances of this case, it was constitutionally permissible to house Taylor in such deplorably unsanitary conditions for such an extended period of time.” The Court went on. No evidence demonstrated that Taylor’s confinement in these particular cells was compelled by “necessity or exigency.” In addition, no evidence revealed a reason to suspect that the conditions could not have been mitigated “in degree or duration.” In sum, the Court found that “any reasonable officer should have realized that Taylor’s conditions of confinement offended the Constitution.”
The Court then vacated the Fifth Circuit’s decision, and remanded the case for further proceedings.
Read the full case: Taylor v. Riojas
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