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United States Supreme Court Rules in Favor of Inmate; Denies Officers Qualified Immunity


The United States Supreme Court in favor of an inmate in Taylor v. Riojas, a decision that was issued yesterday.

What happened in Taylor?

Texas inmate Trent Taylor was subjected to inhumane conditions in his Texas jail cell, after being committed to the unit following a suicide attempt.  The conditions described were horrifying.  Taylor was stripped naked and placed in a cell covered in feces from previous residents.  The feces contaminated his water supply, leading Taylor to not eat or drink for four days out of fear of becoming ill.   Correctional officers then moved Taylor to another cell, which was equally horrific.  The second cell was a “seclusion cell” with no bed or other furniture,  and no toilet to use, just a drain for bodily fluids.  As if the conditions would not get worse, the cell was frigidly cold, and Taylor had nothing but a suicide blanket for warmth.  He was forced to sleep on the urine-soaked floor.  As a result of these conditions, he could not use the bathroom for over 24 hours, and as a result, Taylor suffered a distended bladder requiring catheterization.

Issue of Qualified Immunity

The Fifth Circuit correctly held that the conditions of Taylor’s imprisonment clearly violated the Eighth Amendment, but that the prison officials did not have fair warning that this cell, covered with human waste, would be a violation of the constitution.  Thus, the Fifth Circuit held that the officers responsible had qualified immunity.  “Qualified immunity shields an officer from a lawsuit when he makes a decision that, even if constitutionally deficient, reasonably misapprehends the law governing the circumstances he confronted.”  Brosseau v. Haugen, 543 U. S. 194, 198 (2004).

Qualified immunity has long been controversial because it shields officers from various forms of obvious wrongdoing, and strips individuals of their constitutional protections that are so often violated by police officers.  However, the Supreme Court held that the doctrine could not apply to this case because no reasonable correctional officer would have concluded that it was constitutional to house Taylor in such disgusting and inhumane conditions.

The officers, in fact, did not make a mistake or were unaware of Taylor’s condition. In fact, according to the record, the officers seemed to take humor in the fact that Taylor was confined to a tiny, cold, dirty cell.  Some quotes from the correctional officers include, [Taylor] is “going to have a long weekend,” which was a comment made upon viewing the conditions of the cell.  When Taylor was placed in another cell, the officer told Taylor that he hoped he’d “f***ing freeze”

The COVID-19 pandemic has spread rapidly throughout various American prisons.  With the pandemic affecting everyone’s lives, sanitation and cleanliness have become a huge part of everyday life.  Keeping an inmate in a disgusting cell at the height of a global pandemic is cruel and usual.  Any reasonable person, officer or not, could look at these conditions and determine that they were torturous and unconstitutional.  The Supreme Court was made the right decision in denying these officers qualified immunity.

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