Covalt v. Inmate Services Corporation, 658 F. App'x 367

Christopher Covalt, a pretrial detainee, sued under 42 U.S.C. § 1983 alleging unconstitutional conditions during a non-stop, seven-day van transport from Texas to Wyoming.
Named defendants included Inmate Services Corporation, two of its employees, and various state officials involved in the transport.
Alleged deprivations: inability to sleep (handcuffed, sitting up), only three small cups of water per day, insufficient/unhealthy food, no exercise, infrequent bathroom breaks (urinating in pants), inability to clean after defecation (rash), no showers or clothes changes (bad odor), exposure to secondhand smoke, unsafe driving and occasional unbelted seating, and failure to stop harassment by another passenger.
District court screened and dismissed the complaint under 28 U.S.C. § 1915A for failure to state a claim.
On appeal, the Tenth Circuit reviewed de novo and construed Covalt’s pro se complaint liberally but affirmed the dismissal, holding the alleged conditions did not meet the objective component of a due-process/Eighth-Amendment benchmark claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Covalt alleged objectively sufficiently serious conditions of confinement to state a due-process/Eighth Amendment claim	Conditions on the seven-day transport (sleep deprivation, inadequate water/food, sanitation, safety risks, etc.) amounted to a substantial risk of serious harm	Conditions, while unpleasant, did not rise to the level of depriving minimal civilized necessities or creating substantial risk of serious harm	Court: Allegations did not satisfy the objective component; dismissal affirmed

Kay v. Bemis, 500 F.3d 1214 (10th Cir. 2007) (standard of review for dismissal under § 1915(e)(2)(B)(ii))
Hogan v. Winder, 762 F.3d 1096 (10th Cir. 2014) (plausibility standard for pleading claims)
Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991) (liberal construction of pro se complaints)
Craig v. Eberly, 164 F.3d 490 (10th Cir. 1998) (Due Process governs pretrial detainee conditions; Eighth Amendment used as benchmark)
Mata v. Saiz, 427 F.3d 745 (10th Cir. 2005) (plaintiff must produce objective evidence that deprivation was sufficiently serious)
DeSpain v. Uphoff, 264 F.3d 965 (10th Cir. 2001) (conditions must pose substantial risk of serious harm)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard and substantial risk formulation)
Wilson v. Seiter, 501 U.S. 294 (1991) (only deprivations denying minimal civilized measure of life’s necessities are Eighth Amendment violations)
Gee v. Pacheco, 627 F.3d 1178 (10th Cir. 2010) (example of sufficiently serious transport conditions where plaintiff was denied food and water and physically restrained)
Fogle v. Pierson, 435 F.3d 1252 (10th Cir. 2006) (denial of outdoor exercise for years can be sufficiently serious)
McBride v. Deer, 240 F.3d 1287 (10th Cir. 2001) (living in a feces-covered cell for days was sufficiently serious)