Texas prisoner Trent Taylor alleged that for six full days in September 2013 guards placed him in two shockingly unsanitary cells. The first was covered, nearly floor to ceiling, in “‘massive amounts of feces’: all over the floor, the ceiling, the walls, and been ‘packed inside the water faucet.’” Taylor did not eat or drink for four days out of fear his food and water would be contaminated.
The second cell was frigidly cold. It was equipped with only a clogged floor drain to dispose of bodily wastes. Taylor held his bladder for over 24 hours, but he eventually involuntarily relieved himself, which caused the floor drain to overflow. Because the cell lacked a bunk and Taylor was confined without clothes, he was forced to sleep naked in sewage.
The district court granted the defendants summary judgment on qualified immunity grounds. On appeal, the Fifth District Court of Appeals properly held Taylor’s conditions of confinement violated the Eight Amendment. Based on its assessment that “The law wasn’t clearly established” that “prisoners couldn’t be housed in cells teeming with human waste” “for only six days,’’ the court concluded the defendants did not have “‘fair warning’ that their specific acts were unconstitutional.’” The appeals court therefore affirmed dismissal based on qualified immunity. See: Taylor v. Stevens, 946 F.3d 211 (5th Cir. 2019).
SCOTUS found that to be in error: “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.”
In a concurring opinion, Justice Alito said the case “is a quintessential example of the kind we almost never review” because the court’s rules provide it does not take cases where the asserted error is “the misapplication of a properly stated rule of law.”
The majority, however, signaled in a footnote a desire to resolve, as the Fifth District noted, “ambiguity in the caselaw” regarding whether “a time period so short [as six days] violated the Constitution.” The Fifth District cited Davis v. Scott, 157 F.3d 1003 (5th Cir. 1998), which held the Eighth Amendment was not violated where the prisoner was detained for three days in a dirty cell without cleaning supplies. “Confronted with the particularly egregious facts of this case,” the Supreme Court ruled, “any reasonable officer should have realized that Taylor’s conditions of confinement offended the Constitution.” The Fifth Circuit’s order was vacated. See: Taylor v. Riojas, 141 S. Ct. 52 (2020).
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Related legal cases
Taylor v. Riojas
|Cite||141 S. Ct. 52 (2020)|
Taylor v. Stevens
|Cite||946 F.3d 211 (5th Cir. 2019)|
|Level||Court of Appeals|
|Appeals Court Edition||F.3d|