Supreme Court issues rare ruling against protections for law enforcement officials
The Supreme Court on Monday overturned a lower court’s decision that granted long-standing protections to corrections officers who allegedly kept an inmate housed in “shockingly unsanitary cells” for six days.
The decision is a rare rebuke to law enforcement officials invoking the controversial legal doctrine known as qualified immunity, which often shields officers from civil lawsuits for illegal conduct.
In its 7-1 decision, the Supreme Court said the horrific conditions described by Trent Taylor, a prison inmate in Texas serving an 11-year sentence for robbery, were so egregious that corrections officers would not be covered by qualified immunity.
Taylor alleged he was transferred to a prison psychiatric unit in Montford, Texas, after attempting suicide. He said he was stripped naked and housed in a cell with human feces that covered nearly every surface and was even packed in the unit’s water faucet.
Fearing that any food or water would be contaminated in those conditions, Taylor allegedly refused to eat or drink anything for the four days he was housed in the cell. He was then moved to a new cell that had no sink, toilet or bed, only a drain that had been overflowing with sewage.
Taylor said he spent two full days in the second cell, still naked, and held his urine for 24 hours until he relieved himself in the clogged drain because prison officials would not take him to a restroom. He said the experience led to a distended bladder requiring the insertion of a catheter.
Taylor sued the prison officials, arguing that his confinement during the six-day period was unconstitutional. The 5th Circuit Court of Appeals agreed that the prison guards’ conduct violated the Eighth Amendment’s prohibition on “cruel and unusual punishment,” but that the officials were entitled to qualified immunity because no court had clearly established that the conditions they imposed on Taylor were unconstitutional.
The Supreme Court disagreed, saying in Monday’s unsigned opinion that “confronted with the particularly egregious facts of this case, any reasonable officer should have realized that Taylor’s conditions of confinement offended the Constitution.”
Justice Clarence Thomas was the only member of the court to dissent from the decision, but he did not issue an opinion. Justice Samuel Alito concurred with the decision to overturn the 5th Circuit’s ruling but said the procedural posture of the case did not make it fit for Supreme Court review.
Justice Amy Coney Barrett did not participate in Monday’s ruling.
Elizabeth Cruikshank, one of Taylor’s attorneys, praised the decision.
“We are thrilled with this morning’s decision from the Supreme Court reaffirming that government officials are not entitled to qualified immunity when their conduct is obviously unconstitutional, regardless of whether there is precedent clearly establishing the violation,” she said in a statement.
“Texas prison officials subjected our client, Trent Taylor, to horrific abuse by keeping him naked in cells covered in human feces for six days. Today the Supreme Court rightly recognized that any reasonable officer should have realized that such conditions offended the Constitution,” Cruikshank added.
The qualified immunity doctrine has come under increased scrutiny amid the nationwide protests against racial injustice and police brutality following the police killing of George Floyd in Minneapolis. Critics of the doctrine argue it imposes overly burdensome hurdles for victims of police brutality to hold officers legally accountable.
For a plaintiff to overcome qualified immunity in a civil lawsuit against law enforcement, they have to show not only that the conduct they allege was illegal but that a prior court had already clearly established it as unlawful, so that a reasonable person would recognize it as such.
The Supreme Court has been unwilling to take up the question of whether qualified immunity should be altered or ended.
A bill passed by the House over the summer would end qualified immunity for law enforcement officials. The GOP-controlled Senate did not take up the measure and instead voted on a Republican-backed measure that, among other things, did not include the qualified immunity provision.
Updated at 12:25 p.m.