Second Circuit: Federal Prisoner States Conditions of Confinement Claim
by David Reutter
The Court of Appeals for the Second Circuit held that a federal prisoner sufficiently stated a claim alleging the conditions of his confinement violated the Eighth Amendment.
The case involved an appeal from a New York federal district court’s order granting a motion to dismiss filed by defendant prison officials. The district court held that FCI Ray Brook prisoner Ellis Walker had failed to present facts to support his claim that conditions at the facility constituted cruel and unusual punishment.
Walker alleged that for 28 months he was held in a cell with five other men. The cell had “inadequate space and ventilation, stifling heat in the summer and freezing cold in the winter,” unsanitary conditions that included urine and feces splattered on the floor, insufficient cleaning supplies and a mattress too narrow for him to lie down on flat. Walker also claimed the cell was noisy and crowded, which made sleep difficult, and that he was at constant risk of violence and serious harm from his cellmates.
The Second Circuit held that those allegations plausibly stated a claim for cruel and unusual punishment. First, the appellate court said it was well settled that exposing prisoners to extreme temperatures without adequate ventilation may constitute a constitutional violation.
Next, the Court of Appeals noted that sleep is critical to human existence, and conditions which prevent sleep have been held to violate the Eighth Amendment. “Further, at least one court recently found that the condition of a prisoner’s mattress may be so inadequate as to constitute an unconstitutional violation,” the appellate court wrote.
Third, it has long been recognized that unsanitary conditions in a prison cell, under egregious circumstances, can rise to the level of cruel and unusual punishment. Such conditions lasting for “mere days” could reach that level.
The failure to provide prisoners with toiletries and other hygiene supplies also can be unconstitutional, as can conditions that place prisoners at a “substantial risk of harm.” The Court of Appeals found that Walker had pled sufficient facts to defeat a motion to dismiss, which treats all factual allegations as true, by plausibly alleging “conditions that, perhaps alone and certainly in combination, deprived him of a minimal civilized measure of life’s necessities.”
The Second Circuit held the district court had improperly “assay[ed] the weight of the evidence” and had erred in finding that Walker, who was proceeding pro se, was required to indicate “the exact extent or duration of [his] exposure to unsanitary conditions” and the temperatures in his cell. It had also erred in dismissing Walker’s overcrowding claim by finding the 29 square feet allotted to each prisoner in his six-man cell had been judicially sanctioned in other cases.
The Court of Appeals concluded that Walker was entitled to develop a factual record to support his claims, and that he had adequately alleged the defendants knew about and disregarded the excessive risks to his health and safety at FCI Ray Brook. The Second Circuit declined to address the defendants’ argument that they were entitled to qualified immunity. The district court’s order of dismissal was vacated and the case remanded for further proceedings, where it remains pending. See: Walker v. Schult, 717 F.3d 119 (2d Cir. 2013).
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Related legal case
Walker v. Schult
|717 F.3d 119 (2d Cir. 2013)
|Court of Appeals
|Appeals Court Edition