712 F. App'x 78
2d Cir.2018Background
- Plaintiff Shondell Paul, a pro se inmate in Clinton Correctional Facility’s Special Housing Unit, alleged denial of long underwear and adequate winter clothing for outdoor exercise.
- Paul claimed the lack of proper winter clothing prevented participation in daily outdoor exercise and that he complained to Superintendent LaValley and Deputy Superintendent Brown without remedy.
- Defendants moved for summary judgment on the merits and on qualified immunity grounds; the magistrate judge recommended denying summary judgment.
- The district court adopted much of the magistrate judge’s report but granted qualified immunity to the defendants, concluding it was objectively reasonable for them to deny long underwear.
- The Second Circuit reviewed de novo, found genuine disputes of material fact on the merits, and held the right to exercise opportunities was clearly established at the relevant time.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of long underwear and winter clothing violated Eighth Amendment conditions-of-confinement rights | Paul: Lack of clothing and resulting inability to exercise constituted a sufficiently serious deprivation and demonstrated deliberate indifference | LaValley/Brown: Denial was lawful and not constitutionally inadequate; they reasonably believed their actions lawful | Court: Disputed material facts exist; right to exercise opportunity implicated — claim survives summary-judgment review |
| Whether the defendants are entitled to qualified immunity | Paul: Right to some outdoor exercise was clearly established; officials should have known denial was unconstitutional | Defs: They reasonably believed denying long underwear was lawful, so qualified immunity applies | Court: Right was clearly established; objective-reasonableness defense fails where law was clearly established — qualified immunity denied |
| Proper standard for assessing claimed reasonable belief in lawfulness | Paul: Not separately applicable where right is clearly established | Defs: Claimed objectively reasonable belief that conduct was lawful is a defense | Court: Clarified that whether a right is clearly established is the dispositive inquiry; a defendant cannot prevail by claiming an objectively reasonable belief when law was clearly established |
| Whether summary judgment was appropriate | Paul: Genuine disputes of material fact preclude summary judgment | Defs: Asserted entitlement to judgment as matter of law on merits and immunity | Court: Summary judgment improper as to qualified immunity; remanded for further proceedings |
Key Cases Cited
- Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (qualified-immunity framing: plaintiff must show violation and that right was clearly established)
- Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate-indifference standard for conditions of confinement)
- Rhodes v. Chapman, 452 U.S. 337 (1981) (prison officials must provide life’s necessities)
- Anderson v. Coughlin, 757 F.2d 33 (2d Cir. 1985) (prisoners must be afforded some opportunity for exercise)
- Williams v. Greifinger, 97 F.3d 699 (2d Cir. 1996) (right to opportunity for exercise was clearly established for qualified-immunity purposes)
- Okin v. Village of Cornwall-on-Hudson Police Dep’t, 577 F.3d 415 (2d Cir. 2009) (clarifies that objectively-reasonable-belief defense collapses into clear-establishment inquiry)
- Harlow v. Fitzgerald, 457 U.S. 800 (1982) (qualified-immunity standard)