Taylor v. Riojas

Supreme Court of the United States · 2020 · Torts

TortsEighth AmendmentQualified ImmunityConditions of Confinementqualified immunityEighth Amendmentcruel and unusual punishmentconditions of confinement

Facts

Taylor, a Texas inmate, alleged that correctional officers confined him for six full days in two shockingly unsanitary cells. The first cell was covered nearly floor to ceiling in massive amounts of feces, including on the floor, ceiling, walls, window, and packed inside the water faucet, causing Taylor to avoid eating or drinking for nearly four days out of fear of contamination. Officers then moved him to a frigidly cold second cell with only a clogged floor drain for bodily waste disposal. Because the cell had no bunk and Taylor had no clothing, after the drain overflowed with raw sewage he was left to sleep naked in sewage.

Issue

Whether correctional officers were entitled to qualified immunity for confining Taylor for six days in these extreme unsanitary conditions because no prior case had clearly established that such conduct was unconstitutional for that specific duration. More specifically, the question was whether any reasonable officer should have understood that these conditions of confinement violated the Eighth Amendment.

Rule

Qualified immunity does not shield an officer when, even without a materially identical precedent, a general constitutional rule applies with obvious clarity to the specific conduct at issue. Under extreme and particularly egregious conditions of confinement, no reasonable correctional officer could conclude it is constitutionally permissible to house an inmate in deplorably unsanitary conditions for an extended period of time.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At a jail in Phoenix, correctional officers kept Leon Barrett in a holding cell for five days. The walls, floor, and sink were smeared with human feces, the toilet would not flush, and the officers laughed when Leon asked to be moved; there was no evidence of an emergency or shortage of other cells. Leon sues under the Eighth Amendment, and the officers argue qualified immunity because no prior case involved exactly five days in those precise conditions.

How should the court rule on the qualified-immunity defense at summary judgment, viewing disputed facts in Leon's favor?

Explanation. Qualified immunity does not protect officers when a general constitutional rule applies with obvious clarity to especially egregious conduct. Under the majority opinion, extreme, deplorably unsanitary conditions involving human waste over an extended period can be so obvious that no closely analogous precedent is needed. The absence of necessity or exigency reinforces that result. (Derived from Taylor v. Riojas (n.d.).)