Chilton v. Walters, 3:21-cv-01312

Plaintiff Kristopher Chilton, a TCI inmate, alleges that after an October 2019 visit he was placed on dry-cell watch in the R&D unit and confined for nine days in an empty concrete room.
While confined he wore only a paper gown, had no mattress or blanket, had no sink or flushable toilet, and used a five-gallon bucket for toileting that was not emptied until his release.
Chilton sued several TCI officials under 42 U.S.C. § 1983 for Eighth Amendment violations, seeking compensatory damages and injunctive/declaratory relief.
Served defendants moved to dismiss for failure to state a claim; Chilton did not file an opposition and waived response.
The court found the alleged conditions—temporary (nine days) lack of bedding, nonflushable toileting, and cold cell exposure—were unpleasant but not the “extreme deprivation” required for an Eighth Amendment violation, and dismissed the complaint.
The court also dismissed damages claims under 42 U.S.C. § 1997e(e) for failure to allege a specific non–de minimis physical injury and certified that an appeal would not be taken in good faith.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do nine days without mattress/blanket constitute an Eighth Amendment violation?	Chilton: deprivation of mattress/blanket for nine days was cruel and unusual.	Defs: temporary floor-sleeping is an uncomfortable but not constitutionally severe condition.	Court: No Eighth Amendment violation; nine-day deprivation is a temporary inconvenience.
Does use of a nonflushable bucket toilet for nine days violate the Eighth Amendment?	Chilton: lack of sink/toilet and use of bucket was unconstitutional.	Defs: temporary nonflushable toileting does not meet constitutional minimums.	Court: No; temporary use of nonflushable toileting did not amount to an extreme deprivation.
Do cold temperatures plus lack of clothing/blanket amount to unconstitutional conditions?	Chilton: cold air, paper gown, and no blanket caused an unconstitutional risk to health.	Defs: short-term exposure (nine days) without specific injury is not a constitutional violation.	Court: No; duration and lack of specific injury foreclose an Eighth Amendment claim.
Are Chilton's damages claims barred by § 1997e(e) or procedural waiver?	Chilton: seeks compensatory damages and alleges physical injury.	Defs: complaint alleges no specific physical injury; plaintiff also failed to oppose the motion to dismiss.	Court: Damages dismissed under § 1997e(e) for failure to plead a specific non–de minimis physical injury; plaintiff also waived opposition by not responding.

Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for prison conditions)
Hudson v. McMillian, 503 U.S. 1 (Eighth Amendment requires "extreme deprivation")
Rhodes v. Chapman, 452 U.S. 337 (conditions must deprive minimal civilized measure of life’s necessities)
Wilson v. Seiter, 501 U.S. 294 (conditions may combine to produce a single deprivation such as warmth)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must plead plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards and plausibility)
Knop v. Johnson, 977 F.2d 996 (temporary use of nonflushable toilets not per se Eighth Amendment violation)
Dellis v. Correctional Corp. of Am., 257 F.3d 508 (temporary inconveniences do not necessarily violate Eighth Amendment)
Spencer v. Bouchard, 449 F.3d 721 (consider circumstances, nature, and duration of deprivation)
Hensley Mfg. v. ProPride, Inc., 579 F.3d 603 (pleading plausibility standard application)
Richko v. Wayne County, 819 F.3d 907 (subjective deliberate indifference elements)
Rouster v. County of Saginaw, 749 F.3d 437 (deliberate indifference framework)
Trammell v. Keane, 338 F.3d 155 (temporary deprivation of clothing and bedding not necessarily an Eighth Amendment violation)