In their orders on Monday, the justices struck down a ruling by the U.S. Court of Appeals for the 5th Circuit that had blocked a Texas inmate’s lawsuit against prison officials. The inmate, Trent Taylor, was forced to spend six days naked in cells that contained feces from previous occupants and overflowing sewage. Taylor alleged that prison officials’ conduct violated the Eighth Amendment’s ban on cruel and unusual punishment, but the 5th Circuit, invoking a doctrine known as qualified immunity, ruled that the officials could not be sued because it was not “clearly established” that their conduct violated Taylor’s constitutional rights. Taylor went to the Supreme Court in April, asking the justices to clarify what it means for a constitutional violation to be clearly established.
In a brief unsigned opinion on Monday, the Supreme Court invalidated the 5th Circuit’s decision, without calling for briefing on the merits or oral argument. The justices acknowledged that qualified immunity protects an official who makes a decision that, “even if constitutionally deficient, reasonably misapprehends the law governing the circumstances she confronted.” But in this case, the justices emphasized, “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.” The court of appeals, the court noted, did not identify any emergency or other need for the prison officials to hold Taylor in these conditions, and the record in the case suggests that at least some of the officials were well aware of – but ignored – the conditions in the cells: One officer, putting him in a cell that was covered with feces, said to another officer that Taylor would “have a long weekend,” while a second officer, putting Taylor in a “frigidly cold” cell, expressed hope that Taylor would “f***ing freeze.” The justices sent the case back to the lower court to allow Taylor’s lawsuit to move forward.
