Prison Officials Actions to Correct Inhumane Cell Conditions Merit Judgement in Their Favor
The Seventh Circuit Court of Appeals affirmed an Illinois district court’s summary judgment dismissal of a prisoner’s claim that he was subjected to inhumane conditions and denial of medical care. The Court’s ruling found that the defendants were not deliberately indifferent to the conditions the prisoner alleged.
The court’s June 28, 2021, opinion was issued in an appeal brought by Illinois prisoner Adrian Thomas. He sued several officials at Pontiac Correctional Center.
Thomas alleged that on October 24, 2017, he was moved to a new cell, and its conditions were disgusting. He claimed there were feces, urine, and mold smeared on the walls, sink, and cell door. The mattress was soiled with feces and reeked of urine, over 100 dead flies were on the bunk bed, and the sink emitted only cold, black, and oily water.
Prison officials responded to Thomas’s grievances. After about two weeks, he was given a new mattress, they said. Thomas admitted he used his sheets and blanket to avoid contact with the soiled mattress. He was also given a towel and disinfectant during his eight-week stay in the cell to clean the filth away. The feces stayed in the cell because, as Thomas indicated, he failed to use the disinfectant to clean the walls.
Prison officials also attempted unsuccessfully to fix the plumbing to get hot water in the cell. There was no evidence the water was unfit for consumption, and reports showed it passed regular testing.
Finally, Thomas asserted the cell’s condition caused him to develop a rash. The evidence, however, showed he suffered only a small, clogged pore on his back that was treated with a warm compress to clear up.
Based upon the actions taken by the prison officials, the district court found the defendants were not deliberately indifferent to the conditions of Thomas’s confinement or to his medical needs. As a result, it granted the defendants summary judgment. Thomas appealed.
The Seventh Circuit said that the “initial cell conditions Thomas described, if true, were inhumane, as they posed an excessive risk to his health and deprived him of the ‘minimal civilized measure of life’s necessities.’” That, however, did not end the matter.
The Court found the district court was correct in finding no constitutional violation existed because the defendants responded to correct those conditions and they were not deliberately indifferent to Thomas’s plight. This applied to both the cell’s conditions and Thomas’s medical condition. The district court’s order was affirmed. See: Thomas v. Blackard, 2 F.4th 716 (7th Cir. 2021).
Related legal case
Thomas v. Blackard
|2 F.4th 716 (7th Cir. 2021)
|Court of Appeals