Taylor v. Riojas, 592 U.S. 7

Trent Taylor, a Texas inmate, alleges he was confined for six days in two extremely unsanitary cells: the first nearly floor-to-ceiling covered in feces (food and water feared contaminated), and the second cold, without a bunk, with a clogged drain that overflowed raw sewage while he slept naked.
Taylor stopped eating/drinking for days and alleges severe humiliation and health risk; officers reportedly made hostile remarks when placing him in the cells.
At summary judgment the Fifth Circuit accepted Taylor’s verified pleadings as competent evidence, concluded the alleged conditions would violate the Eighth Amendment, but granted qualified immunity because it found the law was not clearly established for a six-day placement in filthy cells.
The Supreme Court (per curiam) held the Fifth Circuit erred: under these extreme facts no reasonable correctional officer could have believed such confinement was constitutional, and thus qualified immunity was inappropriate.
The Court vacated the Fifth Circuit’s judgment and remanded for further proceedings; it emphasized lack of evidence of necessity or inability to mitigate and pointed to facts suggesting deliberate indifference.
Justice Alito concurred in the judgment but criticized the Court’s decision to grant certiorari; Justice Barrett did not participate and Justice Thomas dissented.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the alleged cell conditions violated the Eighth Amendment	Taylor: confinement in cells covered with feces and later in sewage for days constituted cruel and unusual punishment	Officers: disputed or justified under precedent and facts	Court: The alleged conditions, if proved, constitute an Eighth Amendment violation
Whether officers are entitled to qualified immunity (was the law "clearly established")	Taylor: no reasonable officer could think placing an inmate in those extreme conditions for that duration was constitutional	Officers: law is ambiguous (citing Hutto dictum, Davis) so they lacked fair warning	Court: Law was clearly established as applied to these extreme facts; qualified immunity improper
Whether Supreme Court review was appropriate at this stage	Taylor: sought reversal of qualified-immunity ruling now	Respondents: lower-court resolution final enough; review arguably premature	Court: granted certiorari and vacated/remanded; Alito concurred only in judgment and argued review was unnecessary

Hope v. Pelzer, 536 U.S. 730 (2002) (qualified immunity requires "fair warning" that conduct is unlawful)
Brosseau v. Haugen, 543 U.S. 194 (2004) (qualified immunity protects officers who reasonably misapprehend governing law)
Hutto v. Finney, 437 U.S. 678 (1978) (discussed tolerability of holding a prisoner in a "filthy" cell for "a few days")
United States v. Lanier, 520 U.S. 259 (1997) (a general constitutional rule may apply with obvious clarity to specific conduct)
Davis v. Scott, 157 F.3d 1003 (5th Cir. 1998) (no Eighth Amendment violation where inmate detained three days in a dirty cell)
Taylor v. Stevens, 946 F.3d 211 (5th Cir. 2019) (Fifth Circuit found Eighth Amendment violation but granted qualified immunity)