Lawsuit Over Hellish 9-Day Prisoner Transport Reinstated
The lawsuit was filed by Danzel Stearns. Two ISC employees picked him up in Colorado Springs, Colorado, on September 17, 2016, under contract with Union County, Mississippi, to extradite him to the county courthouse in New Albany to stand trial on a charge there. The firm, based in West Memphis, Tennessee, should have covered the 1,145-mile trip in less than 17 hours.
But instead of heading east toward Mississippi, its drivers headed west and “wandered through 13 states,” passing through some twice to pick up and drop off as many as 17 other prisoners and detainees at a time and overcrowding the van “before finally delivering a sick, sleep-deprived Stearns for prosecution on a minor drug charge,” his suit stated.
The transport made no overnight or lengthy stops. The two drivers took turns sleeping on a mattress in the front of the vehicle. Meanwhile, the detainees remained in upright positions, making it difficult to sleep for any period beyond “cat naps.”
There were no bathrooms in the vehicles, which forced some detainees to urinate in cups that ultimately spilled onto the floor. One female defecated in her pants, Stearns alleged, after her repeated requests for a bathroom break were ignored. He developed “clogs of manure” in his pants that caused perianal irritation from not being able to properly clean himself. He was not allowed to change clothes or shower during the trip. Upon arrival in Mississippi, Stearns discovered ringworm on his stomach.
Stearns’ complaint alleged violations of the Fourth, Eighth, and Fourteenth amendments. “The unnecessarily prolonged transport, fully chained, immobile, with no opportunity to wash even his hands, to change clothes, or to use the toilet more than irregularly and while chained, and able only to snatch an occasional nap while sitting up on hard seats for nine continuous days” violated Stearns’ Eighth Amendment right to be free from cruel and unusual punishment, the complaint alleged.
The district court denied ISC’s motion for summary judgment under the Prison Litigation Reform Act, but it granted a second motion to dismiss charges of excessive use of force, inadequate medical care and improper conditions of confinement. Stearns appealed.
The Eighth Circuit analyzed Stearns’ claim under the Fourteenth Amendment and Bell v. Wolfish, 441 U.S. 520 (1979), which holds that “due process requires a pretrial detainee not be punished.” Under Bell, the appeals court ruled, the district court was required to focus on ISC’s policies or customs to determine whether Stearns’ confinement conditions were reasonably related to a legitimate goal or were excessive as compared to that goal. If excessive, then the conditions might constitute punishment, from which Bell explicitly protects detainees.
The court found that “Stearns was subjected to painful, unsanitary, and severe conditions and restraints for over one week.” Yet ISC’s representation in its contract was for “a much shorter contract of no more than 24 hours.” The Court then looked to the totality of the circumstances.
Under ISC’s policy, Stearns was kept in handcuffs and leg shackles connected to a belly chain during the entirety of the transport, in violation of another company policy that restraints be removed “from inmates that are on transport more than 48 hours.” Its policy also provided he be given water and fast food, but he was provided only limited amounts. ISC’s policies also contemplate “transports as long as 7 to 10 days,” and the evidence showed its practice is to pick up and drop off prisoners on multi-state journeys such as Stearns.
In reversing the district court’s order, the Eighth Circuit concluded a jury could find the totality of the circumstances endured by Stearns violated his Fourteenth Amendment right to be free of punishment, remanding the case to the district court for reconsideration. See: Stearns v. Inmate Services Corp., 957 F.3d 902 (8th Cir. 2020).
Related legal case
Stearns v. Inmate Services Corp.
|Cite||957 F.3d 902 (8th Cir. 2020)|
|Level||Court of Appeals|
|Appeals Court Edition||F.3d|