Inmate is entitled to sue over claim his cell had 'massive amounts' of feces, SCOTUS rules
Image from Shutterstock.com.
Prison officials don’t have qualified immunity from a lawsuit by an inmate who claims that he was held in a cell covered in “massive amounts” of feces, the U.S. Supreme Court ruled Monday in a per curiam opinion.
The 5th U.S. Circuit Court of Appeals at New Orleans erred in granting qualified immunity in the case brought by Texas inmate Trent Taylor, the Supreme Court said.
The 5th Circuit had held that Taylor’s allegations, if proven, would violate the Eighth Amendment’s ban on cruel and unusual punishment. But prison officials were entitled to qualified immunity because the law wasn’t clearly established that prisoners couldn’t be held in such conditions.
The Supreme Court disagreed.
“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 high court said.
Taylor had alleged that he was held in two unsanitary sells for six days in September 2013. The first cell was covered in feces all over the floor, the ceiling, the walls and even “packed inside the water faucet,” Taylor said. Fearing that his food and water would be contaminated, Taylor didn’t eat or drink for nearly four days, he said.
Taylor was then moved to a second, frigidly cold cell that had only a clogged drain to dispose of bodily wastes, according to his lawsuit. He tried holding his bladder for 24 hours but involuntarily relieved himself, causing the drain to overflow. The cell had no bunk, and Taylor was confined without clothing, so he had to sleep naked in raw sewage, he had alleged.
The Supreme Court granted cert, vacated the judgment and remanded the case.
Justice Clarence Thomas dissented without an opinion. Justice Amy Coney Barrett did not participate in the case. A Supreme Court spokeswoman said Barrett did not participate in any cases considered by the Supreme Court at its case conference last week, SCOTUSblog reports.
Justice Samuel A. Alito Jr. wrote an opinion concurring in the judgment but disagreeing with the decision to grant cert. Alito said the Supreme Court was disagreeing with the 5th Circuit’s application of the facts to the law, and the case is “a quintessential example of the kind that we almost never review.”
The case is Taylor v. Riojas.