On July 8, 2022, a Texas prisoner’s decade-long legal battle over grossly unsanitary conditions in his cell finally came to an end, when he stipulated to dismissal of his lawsuit against the state Department of Criminal Justice (TDCJ) after accepting a $50,000 settlement.
For six days in September 2013, guards at the Montford Unit kept Trent Michael Taylor in cells that were simply disgusting, he said. The first was covered in feces almost completely – the floor, walls and even the water faucet. After four days Taylor was moved to another cell, but this one was extremely cold and had a clogged floor drain that served as a toilet. Taylor, who was naked, had to sleep on the floor in his own waste because the cell had no bunk.
Taylor filed suit pro se, but the federal court for the Northern District of Texas granted Defendants qualified immunity (QI) and dismissed the complaint, a decision affirmed by the U.S. Court of Appeals for the Fifth Circuit on December 20, 2019. While the cell conditions that Taylor described amounted to the sort of “cruel and unusual punishment” prohibited by the Eighth Amendment, it was not clearly established at the time that “only six days” in such conditions was unconstitutional, the Fifth Circuit said, noting “ambiguity in the caselaw.”
Then the U.S. Supreme Court reversed that ruling on November 2, 2020. Stripping the guards of QI, the high court said “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.” Justice Samuel Alito filed a separate concurring opinion, while Justice Clarence Thomas dissented. [See: PLN, July 2021, p.32.]
On remand back at the district court, Taylor picked up representation by Austin attorneys Jay. D. Ellwanger and David W. Henderson of Ellwanger Henderson LLLP. His only remaining claims related to the six days he spent in the unsanitary cells; previous dismissals had been affirmed of other claims concerning excessive use of force, inadequate medical care and due-process violations.
The parties then reached their settlement agreement on February 10, 2022. Under its terms, $32,885.27 was payable to Taylor and $17,114.73 allocated for fees and costs to his attorneys. See: Taylor v. Riojas, U.S.D.C. (N.D. Tex.), Case No. 5:14-cv-00149.
That it took the nation’s highest court to find even a potential constitutional violation in what were such obviously egregious conditions demonstrates the high bar that prisoners must overcome to prevail in civil rights cases.
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