Taylor v. Riojas, 592 U.S. ___ (2020)
Taylor, a Texas inmate, alleges that in September 2013, correctional officers confined him in a cell covered, nearly floor to ceiling, in “ ‘massive amounts’ of feces.” Taylor did not eat or drink for nearly four days. Officers then moved Taylor to another, frigidly cold cell, which was equipped with only a clogged floor drain to dispose of bodily wastes. Taylor held his bladder for over 24 hours, but eventually, involuntarily relieved himself, causing the drain to overflow and raw sewage to spill across the floor. The cell lacked a bunk and Taylor was confined without clothing; he was left to sleep naked in sewage.
The Fifth Circuit held that such conditions of confinement violate the Eighth Amendment’s prohibition on cruel and unusual punishment but, concluding that “[t]he law wasn’t clearly established” that “prisoners couldn’t be housed in cells teeming with human waste” “for only six days,” the court held that the prison officials did not have “ ‘fair warning’ that their specific acts were unconstitutional.”
The Supreme Court vacated. The officers were not entitled to qualified immunity; no reasonable correctional officer could have concluded that, under these extreme circumstances, it was constitutionally permissible to house Taylor in such deplorably unsanitary conditions for an extended period of time. There was no evidence that the conditions of Taylor’s confinement were compelled by necessity or exigency nor that those conditions could not have been mitigated, either in degree or duration. While an officer-by-officer analysis will be necessary on remand, the record suggests that at least some officers involved in Taylor’s ordeal were deliberately indifferent to the conditions of his cells.
Supreme Court vacates a grant of qualified immunity: No reasonable correctional officer could have concluded that the confinement of an inmate, for several days, in a cell filled with sewage, was constitutionally permissible.
JUDGMENT ISSUED. |
Petition GRANTED. Judgment VACATED and case REMANDED for further proceedings consistent with this opinion. Justice Barrett took no part in the consideration or decision of this case. Justice Thomas dissents. Justice Alito, concurring in the judgment. Opinion per curiam. (Detached Opinion) |
Petition GRANTED. Judgment VACATED and case REMANDED for further proceedings consistent with this opinion. Justice Barrett took no part in the consideration or decision of this case. Justice Thomas dissents. Justice Alito, concurring in the judgment. Opinion per curiam. (Detached Opinion) |
DISTRIBUTED for Conference of 10/30/2020. |
DISTRIBUTED for Conference of 10/16/2020. |
Record received from the U.S.D.C. for the Northern District of Texas. The electronic record on appeal (including sealed materials) was received. |
Record received from the U.S.C.A. for the Fifth Circuit. The record is available on PACER. |
DISTRIBUTED for Conference of 10/9/2020. |
Record Requested. |
DISTRIBUTED for Conference of 9/29/2020. |
Reply of petitioner Trent Michael Taylor filed. (Distributed) |
Brief of respondents Robert Riojas, et al. in opposition filed. |
Brief amicus curiae of Constitutional Accountability Center filed. |
Brief amici curiae of Cross-Ideological Groups Dedicated to Ensuring Official Accountability, Restoring the Public's Trust in Law Enforcement, and Promoting the Rule of Law filed. |
Motion to extend the time to file a response is granted and the time is extended to and including July 1, 2020. |
Motion to extend the time to file a response from June 1, 2020 to July 1, 2020, submitted to The Clerk. |
Petition for a writ of certiorari filed. (Response due June 1, 2020) |