In Taylor v. Riojas, published November 2, 2020, the Supreme Court reversed a circuit court's ruling that correctional officials were entitled to summary judgment in a 42 U.S.C. section 1983 case. The inmate alleged that for six days he was confined to two unsanitary cells. The first was allegedly covered nearly floor to ceiling in massive amounts of feces. The second was frigidly cold, had no bunk, and had only a clogged drain in the floor to dispose of bodily wastes. The plaintiff was allegedly confined without clothing and had to sleep naked in sewage. The circuit court held that the conditions violated the inmate's Eighth Amendment right to be free of cruel and unusual punishment; but that the prison officials were entitled to qualified immunity, because the law was not clearly established that prisoners could not be housed in cells teeming with human waste for six days.
The Supreme Court ruled that the circuit erred in granting qualified immunity on that basis. No reasonable correctional officer could have concluded that, under the extreme circumstances of this case, it was constitutionally permissible to house the inmate in such deplorably unsanitary conditions for such an extended period of time. The circuit cited no evidence that the confinement was compelled by necessity or exigency. There was no evidence the conditions could not be mitigated in degree or duration. There was evidence, based on officers' statements, that they were deliberately indifferent to the condition of the cells. Other case law was too dissimilar to create any doubt about the obviousness of the inmate's right.
Justice Thomas dissented, but did not write a separate opinion. Justice Barrett did not take part in the consideration or decision. Justice Alito concurred but opined the court should not have granted review.
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