Walker v. Schult
2013 U.S. App. LEXIS 10397
| 2d Cir. | 2013Background
- Walker, pro se plaintiff, sued federal officials alleging Eighth Amendment cruel and unusual punishment due to prison conditions at FCI Ray Brook.
- He was housed in a six-man cell from Nov 18, 2008 for about 28 months, occupying 170–174 sq ft with roughly 28–29 sq ft per inmate and limited moving space.
- Cell conditions included a narrow top bunk without ladders, lack of adequate ventilation, extreme temperatures, noise, and overcrowding.
- Sanitation was inadequate (urine/feces on floors, insufficient cleaning supplies); inmates had to use personal cleaning agents to maintain hygiene.
- Walker informed officials of overcrowding, noise, ventilation, and bed-width problems; he pursued administrative remedies but faced alleged obstruction; the district court dismissed the case for failure to state a claim, leading to this appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Walker stated an Eighth Amendment claim for cruel and unusual confinement | Walker plausibly alleged objective deprivation and risk to health | Defendants contended no plausible deprivation or causative indifference | Plaintiff stated plausible Eighth Amendment claim on both objective and subjective prongs |
| Whether defendants acted with deliberate indifference | Walker alleged defendants knew of overcrowding/noise/ventilation and ignored it | Defendants contended lack of sufficient evidence of intentional disregard at pleading stage | Plaintiff plausibly alleged deliberate indifference at the pleading stage |
| Whether qualified immunity applies at the pleading stage | Rights were clearly established; defendants violated them | Right not clearly established or not violated per se at pleadings stage | Not resolved at pleadings stage; remanded for further development (summary judgment possible) |
Key Cases Cited
- Rhodes v. Chapman, 452 U.S. 337 (U.S. 1981) (constitutionality of crowded cells depends on context and other conditions)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference standard for Eighth Amendment claims)
- Gaston v. Coughlin, 249 F.3d 156 (2d Cir. 2001) (review of knowledge and disregard of excessive risk to inmate health or safety)
- Jabbar v. Fischer, 683 F.3d 54 (2d Cir. 2012) (aggregation of conditions; subjective knowledge element)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (concept of minimal civilized measure of life's necessities and aggregate conditions)