Prisoner allowed to challenge his prison conditions
Ellis Walker, an inmate at the federal prison at Ray Brook, N.Y, may continue his lawsuit against the allegedly deplorable prison conditions, said the U.S. Court of Appeals for the Second Circuit.
Judge Denny Chin, writing the majority opinion, noted that Walker “plausibly alleged conditions that, perhaps alone and certainly in combination, deprive him of a minimal civilized measure of life’s necessities,” and that prison officials were “deliberately indifferent to this deprivation.”
Walker alleged in his complaint that he was placed in a six-man cell, which was not enough space “to even turn or move in.” In addition to the six prisoners, the cell contained their bunk beds, their belongings, two toilets and two sinks.
According to Walker, his cellmates included gang members, and the “overcrowding, gang activities, violence [and] fights” in the cell placed Walker “in a situation to kill or be killed.” Walker also claimed that his cell was unsanitary, with so much “urine on the floor” that “urin[e] or defecat[ion] would splatter.” Walker complained to the warden and other prison officials to no avail.
The government argued that Walker exhausted his available administrative remedies and that an inmate is not at liberty to simply aggregate a collection of claims in order to allege a violation of constitutional rights.
After oral arguments in January, Chin wrote, “Although the Constitution does not require ‘comfortable’ prison conditions, the conditions of confinement may not ‘involve the wanton and unnecessary infliction of pain.’”
Based on Walker’s allegations, the court found that “Walker plausibly alleged that the overcrowding and lack of living space in his cell were exacerbated by the ventilation, noise, sanitation, and safety issues, leading to deprivations of specific life necessities,” and therefore could bring an 8th Amendment challenge for cruel and unusual punishment.
The 2nd Circuit Court of Appeals sent Walker’s case back to the trial court for further proceedings.
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