In re Pers. Restraint of Williams
496 P.3d 289
| Wash. | 2021Background:
- Robert R. Williams, a 77–78-year-old incarcerated man with significant disabilities (post-stroke paralysis, wheelchair-bound, diabetes, hypertension), was housed in a "dry" cell (no sink or toilet) at Coyote Ridge and relied on aides to access restrooms.
- Because aides were often delayed, Williams frequently had to relieve himself in bottles and lacked reasonable access to running water and hygiene, creating objectively degrading conditions.
- Williams sought extraordinary medical placement (home confinement in Florida); DOC denied it for safety reasons, and Williams filed a personal restraint petition (PRP) claiming cruel punishment under WA Const. art. I, § 14 and the Eighth Amendment.
- The Court of Appeals applied a state test and denied relief; the Washington Supreme Court granted review, concluded the state cruel-punishment clause affords greater protection than the Eighth Amendment for prison conditions, and issued an order requiring DOC to remedy Williams’s conditions or release him.
- DOC subsequently moved Williams to assisted-living–style housing with a single cell containing a toilet and sink, ADA-compliant restrooms, assigned aides, and medical support; the Supreme Court declined to order release and explained its legal reasoning.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether WA Const. art. I, § 14 is more protective than the Eighth Amendment for conditions of confinement | Williams: state clause provides broader protection (omits "unusual") and supports relief for cruel conditions regardless of official intent | DOC: national standards and federal framework govern; no divergence intended | Court: Article I, § 14 is more protective in the context of prison conditions; Gunwall factors support independent state analysis |
| What test governs state constitutional challenges to conditions of confinement | Williams: require State to justify continued confinement in light of new data (race, age, disability impacts); lower threshold than Farmer | DOC: federal Farmer deliberate-indifference standard applies | Court: adopts modified test — (1) conditions create objectively significant risk of serious harm or deprive basic human dignity; and (2) conditions are not reasonably necessary to accomplish a legitimate penological goal |
| Whether Williams’s specific conditions violated the state test | Williams: lack of toilet/sink, long waits for assistance, soiling himself — objectively cruel and not justified | DOC: security and community-safety concerns tied to his violent offense justify housing choices | Court: Williams’s confinement deprived him of basic hygienic necessities, created a significant risk of serious harm, and was not reasonably necessary to legitimate penological goals; violated art. I, § 14 |
| Appropriate remedy for unconstitutional conditions | Williams: release to home confinement if DOC cannot remediate | DOC: retain custody and address conditions internally; detention justified by public safety | Court: granted PRP and ordered DOC to remedy conditions or release; after DOC remedied conditions, court declined to order release |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (establishes federal deliberate-indifference test for prison-conditions claims)
- Wilson v. Seiter, 501 U.S. 294 (1991) (addresses the role of subjective intent in Eighth Amendment conditions analysis)
- Rhodes v. Chapman, 452 U.S. 337 (1981) (defines "minimal civilized measure of life’s necessities")
- Colvin v. Inslee, 195 Wn.2d 879 (2020) (recognizes COVID-19 risks in prisons and use of federal standard in prior WA cases)
- State v. Bassett, 192 Wn.2d 67 (2018) (uses state constitution for more protective sentencing analysis; supports evolving state framework)
- Wash. Water Jet Workers Ass’n v. Yarbrough, 151 Wn.2d 470 (2004) (historical context: protection against cruel convict-leasing practices informs state interest in prison conditions)
- In re Pers. Restraint of Williams, 15 Wn. App. 2d 647 (2020) (Court of Appeals decision denying PRP and proposing a three-factor test)
- Gregoire v. City of Oak Harbor, 170 Wn.2d 628 (2010) (recognizes jailer’s special duty to inmate health and safety)
- Shea v. City of Spokane, 17 Wn. App. 236 (1977) (identifies custodial special-relationship duty to ensure prisoners’ welfare)
- Woods v. Burton, 8 Wn. App. 13 (1972) (holds prisons may not impose sanitation/hygiene conditions that offend human dignity)