Supreme Court: Texas inmate’s unsanitary conditions lawsuit against prison officials can proceed
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Supreme Court: Texas inmate’s unsanitary conditions lawsuit against prison officials can proceed

The US Supreme Court on Monday invalidated an order by the US Court of Appeal for the Fifth Circuit that granted prison officers qualified immunity in a lawsuit brought by a Texas inmate.

Inmate Trent Taylor sued ten prison officials within the Texas Department of Criminal Justice for violating his Eighth Amendment rights, when they confined him in two “shockingly unsanitary cells.” Taylor asserted that in 2013, the officers forced him to spend six days in a prison cell covered in human feces and overflowing sewage from previous occupants. Fearing contamination, Taylor did not eat or drink for nearly four days. The officers then moved Taylor to a “second, frigidly cold cell, which was equipped with only a clogged drain in the floor to dispose of bodily wastes.” Taylor was forced to sleep naked on the sewage-covered floor because the cell lacked a bunk.

The Fifth Circuit found that such confinement conditions violated the Eighth Amendment’s prohibition on cruel and unusual punishment. However, the court invoked the doctrine of qualified immunity, and concluded that “the law wasn’t clearly established that prisoners couldn’t be housed in cells teeming with human waste…” and that the prison officers “did not have ‘fair warning’ that their specific acts were unconstitutional.”

In its per curiam opinion, the Court underscored 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.” Further, the Court noted that “the record suggests that at least some officers involved in Taylor’s ordeal were deliberately indifferent to the conditions of his cells.”

“Confronted with the particularly egregious facts of this case, any reasonable officer would have realized that Taylor’s conditions of confinement offended the Constitution.”

Justice Samuel Alito submitted a separate opinion in which he concurred with the judgment, but expressed his confusion as to why the Court’s intervention was even necessary. “The Court does not dispute that the Fifth Circuit applied all the correct legal standards,” he said. “But the Court simply disagrees with the Fifth Circuit’s application of those tests to the facts in a particular record.”

Justice Clarence Thomas dissented from the Court’s opinion but did not provide a written explanation as to why.

Justice Amy Coney Barrett, the Court’s newest member, did not participate in the consideration or decision of the case.