Qualified immunity, a legal doctrine that shields government officials from personal liability for violating constitutional rights in the course of their official duties has become a controversial subject in recent years.
The Supreme Court made a strong statement on the issue Monday, overturning an appeals court decision and opening the door for a Texas inmate to sue six prison officials for violating his Eighth Amendment rights against “cruel and unusual punishment,” The Hill reported.
Inmate forced to live in filth
Trent Taylor, an inmate imprisoned at the John T. Montford Psychiatric Facility Unit in Lubbock, sought to sue six prison officials who he claimed deliberately placed him naked in two filthy cells for six days and refused to move him to a clean cell, The Texas Tribune reported.
For three days Taylor was in the first cell that he claimed was completely covered in feces, which prevented him from eating or drinking for the duration. He was then transferred to a second cell with no bed or toilet and only a clogged floor drain in which he was forced to relieve himself and then remain naked in the overflowing sewage.
The Hill noted that the Fifth Circuit Court of Appeals agreed with Taylor that his Eighth Amendment protection against cruel and unusual punishment had been violated, but held that the six officials were immune from liability since there was no “clearly established” precedent that dealt with similar specifics to this case.
“No reasonable correctional officer”
The Supreme Court, however, ruled that “the Fifth Circuit erred in granting the officers qualified immunity on this basis,” and pointed out that qualified immunity was only applicable when an official who had violated the Constitution was nonetheless reasonably mistaken to believe that they were doing the right thing as per existing law.
“But 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 wrote.
The justices went on to note that there was no known emergency or extenuating circumstances that made Taylor’s situation necessary and it was already apparent that at least some of the prison officials had been “deliberately indifferent to the conditions of his cells.”
“Confronted with the particularly egregious facts of this case, any reasonable officer should have realized that Taylor’s conditions of confinement offended the Constitution,” the court concluded and remanded the case back down to the lower courts to proceed on the merits.
Court ruled 7-1
Justice Samuel Alito offered a separate opinion in which he concurred with the majority but questioned why the high court had taken up the case at all, given that it was not resolving a dispute among lower courts or establishing new legal ground but was merely reviewing and correcting a erroneous ruling.
That said, this ruling likely places the lower courts on notice that the doctrine of qualified immunity is not unquestionable, and in obviously “egregious” cases shouldn’t be so quickly applied to protect officials that should be open to liability for their actions.
Ultimately, the court ruled 7-1 — newly seated Justice Amy Coney Barrett did not participate — that the violations of the inmate’s rights were so “egregious” that the prison officials responsible should not be protected from liability by qualified immunity. Justice Clarence Thomas, who has been critical of the doctrine in the past, was the lone dissenting vote.