Burkle v. Patrick
20-50221
| 5th Cir. | Mar 28, 2025Background
- Texas inmate Jonathan Burkle was suspected of ingesting illicit drugs during a family visit and placed in a hot, unsanitary prison shower cell for approximately 30 hours, during which he was denied food, drinking water, and bathroom access.
- Burkle alleges he experienced symptoms of heat-related illness, defecated and vomited in the shower, and repeatedly requested food, water, medical, and cleaning assistance, all of which were denied.
- Major Anthony Patrick ordered Burkle’s detention and the deprivation of food and water; subordinate officers (Snyder, Wheeler, Han, and Brooks) complied with the order, and other supervisors had no involvement in the day-to-day conditions.
- After collapsing, Burkle was released, provided water, and checked by infirmary staff; he suffered no documented lasting injury but filed a pro se § 1983 suit for Eighth Amendment violations.
- The district court granted summary judgment for all defendants, finding no deliberate indifference or violation, and deemed qualified immunity applicable; Burkle appealed.
- The Fifth Circuit majority affirmed in part and reversed in part: most officers retained qualified immunity for following orders, but the case was remanded against the estate of Major Patrick; a dissent would have denied immunity to some subordinate officers as well.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Conditions of Confinement (Eighth Amendment) | Confinement was cruel/unusual: excessive heat, no food/water, filth | Conditions were temporary, preventive, and not objectively extreme | Mixed: Not Eighth Amendment violation for most, but jury could find violation for Patrick |
| Deliberate Indifference | Officers knew/saw obvious health risks; ignored requests | No subjective awareness of substantial risk; followed superior’s orders | Mixed: No jury question for subordinates, genuine dispute re Patrick |
| Qualified Immunity | Conditions obviously unconstitutional; rights clearly established | No clearly established law covers facts; reasonable officers wouldn’t know | Subordinates entitled; Patrick’s immunity remanded |
| Application of Prison Policy | TDCJ policy required basic entitlements regardless of suspicion | Following penological purpose; deviation not facially outrageous | Deviation not enough to void most officers’ immunity |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (Supreme Court Eighth Amendment deliberate indifference standard)
- Taylor v. Riojas, 592 U.S. 7 (recent Supreme Court damages case finding denial of sanitation/eight amendment violation)
- Gates v. Cook, 376 F.3d 323 (Fifth Circuit, extreme temperature and sanitation conditions violate Eighth Amendment)
- Cooper v. Sheriff, Lubbock County, 929 F.2d 1078 (denial of food as an Eighth Amendment violation)
- Wilson v. Seiter, 501 U.S. 294 (threshold for Eighth Amendment conditions-based claims)
- Hope v. Pelzer, 536 U.S. 730 (qualified immunity/clearly established law for cruel and unusual punishment)
- Rhodes v. Chapman, 452 U.S. 337 (basic minimum needs for prisoners under Eighth Amendment)
- Helling v. McKinney, 509 U.S. 25 (unconstitutional prison conditions even without injury)
- Ball v. LeBlanc, 792 F.3d 584 (Fifth Circuit recognizes extreme temperature risk)
- Palmer v. Johnson, 193 F.3d 346 (totality of conditions relevant to Eighth Amendment assessment)