Gates v. Cook.U.S. Appeals Court LIGHTING HYGIENE TEMPERATURE LAUNDRY Gates v. Cook, 376 F.3d 323 (5th Cir. 2004). A death row prisoner brought a suit on behalf of himself and other prisoners confined to death row, alleging that certain conditions of confinement on death row violated the Eighth Amendment's prohibition against cruel and unusual punishment Such punishment as would amount to torture or barbarity, any cruel and degrading punishment not known to the Common Law, or any fine, penalty, confinement, or treatment that is so disproportionate to the offense as to shock the moral sense of the community. . The district court found that a number of conditions violated the Eighth Amendment and issued an injunction designed to alleviate the conditions. The defendants appealed. The appeals court affirmed in part and vacated in part. The court held that the prison's accreditation by a national correctional association (American Correctional Association The American Correctional Association is an association of providers of services to prisons in the United States. It holds an annual trade show where products used in prisons are shown to prospective purchasers. It was formerly known as the American Prison Association. ) was not proof that the conditions of confinement did not violate the Eighth Amendment. The court noted that compliance with association standards could be a relevant consideration, but was not evidence of constitutionality. The court held that evidence supported findings that the probability of heat-related illness was extreme at the death row unit in which the class members were housed, and that corrections officials had displayed deliberate indifference. The court found that lighting in each death row cell was less than twenty foot-candles, in violation of the constitutional rights of the class members. Expert testimony Testimony about a scientific, technical, or professional issue given by a person qualified to testify because of familiarity with the subject or special training in the field. was presented that lighting in the cells was grossly inadequate for the purposes of sanitation, personal hygiene personal hygiene person n → Körperhygiene f and reading, and that these conditions contributed to further mental health deterioration. The court did not find a constitutional violation in the condition of the inmate laundry, which required inmates to wash their own clothes with bar soap. The court found that parts of the district court injunction that applied to sections of the death row unit that did not house class members exceeded the scope of the litigation An action brought in court to enforce a particular right. The act or process of bringing a lawsuit in and of itself; a judicial contest; any dispute. When a person begins a civil lawsuit, the person enters into a process called litigation. and were invalid. The injunction directed the prison to provide fans, ice water, and daily showers when the heat index was 90 degrees or above, or to make such arrangements from May through September. The court found an Eighth Amendment violation due to mosquito infestation infestation /in·fes·ta·tion/ (-fes-ta´shun) parasitic attack or subsistence on the skin and/or its appendages, as by insects, mites, or ticks; sometimes used to denote parasitic invasion of the organs and tissues, as by helminths. coupled with insufficient screen gauge, which exacerbated the heat problems by deterring death row inmates from opening their windows to increase circulation. The court noted that pest infestation problems were linked to chronic sleep deprivation sleep deprivation Sleep disorders A prolonged period without the usual amount of sleep. See Driver fatigue, Poor sleeping hygiene, Sleep disorders, Sleep-onset insomnia. , which exacerbated the symptoms of mental illness. The court found a violation due to "ping-pong" toilets, and that corrections officials were deliberately indifferent to the risk of harm that these toilets presented to death row inmates. Experts established that a serious health hazard health hazard Occupational safety Any agent or activity posing a potential hazard to health. Cf Physical hazard. resulted when the feces of one inmate bubbled up in the neighboring cell, and that this was exacerbated when toilets overflowed. According to the court, the State Department of Health warned corrections officials every year for the past eleven years that the malfunctioning toilets were a critical public health problem that required immediate attention. According to the court, inmates were afforded insufficient mental health care, in violation of the Eighth Amendment. The court cited the isolation and idleness, squalor, poor hygiene, temperature, and the noise of extremely psychotic prisoners, which created an environment that was "toxic" to the prisoners' mental health. (Mississippi Department of Corrections, Unit 32-C, State Penitentiary penitentiary: see prison. in Parchman) |
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