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Months of Cold-Wet Conditions States Inadequate Shelter Claim
The Sixth Circuit Court of Appeals has held that a Michigan prisoner offered sufficient evidence to support his Eighth Amendment inadequate shelter claim.
The Court's decision came in the appeal of William Spencer, who brought claims relating to his pre-trial detention from August 15, 2001 to February 4, 2002 at the Oakland County Jail, after the district court granted the defendants summary judgment.
Spencer's complaint alleged claims for failure to provide adequate reading material, opening his legal mail, maintaining overcrowded conditions, denying out-of-cell exercise time, and failing to provide adequately warm and dry shelter.
The defendants argued that Spencer had failed to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA). The Sixth Circuit said that under its precedent at the time, a grievance relating to the inadequate shelter claim stated the names of prison officials involved. As such, the Court ordered the district court to dismiss without prejudice all claims other than the inadequate shelter claim.
That claim asserted Spencer was forced to sleep on the floor due to overcrowding. His cell block was "very cold," particularly where Spencer's cell was located. While guards wore winter coats inside, prisoners had only a standard jumpsuit. Extra blankets procured by the prisoners were confiscated.
The worst part, for Spencer, was that whenever it rained or snowed, water leaked "real bad" from the ceiling onto his bed. To remedy the situation, Spencer and other prisoners erected "awnings" out of garbage bags. The Court found the guards' obstruction of prisoners' attempts to help themselves had no penological interest. When Spencer complained to defendant Lieutenant Snarey while he was tearing down an "awning," Snarey replied, "It's your own damn fault you [sic] in here so deal with it."
The Court found the wet and cold conditions would have been obvious to anyone in the vicinity. Additionally, allowing such dangerous, wet conditions to exist for months at a time was a substantial risk that was so obvious it merited no further discussion.
The Sixth Circuit held that Spencer submitted sufficient evidence on his inadequate shelter claim to defeat summary judgment. Accordingly, the district court's order was affirmed in part and reversed in part. See: Spencer v. Bouchard, 449 F.3d 721 (6th Cir. 2006).
The Court's decision came in the appeal of William Spencer, who brought claims relating to his pre-trial detention from August 15, 2001 to February 4, 2002 at the Oakland County Jail, after the district court granted the defendants summary judgment.
Spencer's complaint alleged claims for failure to provide adequate reading material, opening his legal mail, maintaining overcrowded conditions, denying out-of-cell exercise time, and failing to provide adequately warm and dry shelter.
The defendants argued that Spencer had failed to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA). The Sixth Circuit said that under its precedent at the time, a grievance relating to the inadequate shelter claim stated the names of prison officials involved. As such, the Court ordered the district court to dismiss without prejudice all claims other than the inadequate shelter claim.
That claim asserted Spencer was forced to sleep on the floor due to overcrowding. His cell block was "very cold," particularly where Spencer's cell was located. While guards wore winter coats inside, prisoners had only a standard jumpsuit. Extra blankets procured by the prisoners were confiscated.
The worst part, for Spencer, was that whenever it rained or snowed, water leaked "real bad" from the ceiling onto his bed. To remedy the situation, Spencer and other prisoners erected "awnings" out of garbage bags. The Court found the guards' obstruction of prisoners' attempts to help themselves had no penological interest. When Spencer complained to defendant Lieutenant Snarey while he was tearing down an "awning," Snarey replied, "It's your own damn fault you [sic] in here so deal with it."
The Court found the wet and cold conditions would have been obvious to anyone in the vicinity. Additionally, allowing such dangerous, wet conditions to exist for months at a time was a substantial risk that was so obvious it merited no further discussion.
The Sixth Circuit held that Spencer submitted sufficient evidence on his inadequate shelter claim to defeat summary judgment. Accordingly, the district court's order was affirmed in part and reversed in part. See: Spencer v. Bouchard, 449 F.3d 721 (6th Cir. 2006).
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Related legal case
Spencer v. Bouchard
| Year | 2006 |
|---|---|
| Cite | 449 F.3d 721 (6th Cir. 2006) |
| Level | Court of Appeals |
| Injunction Status | N/A |