The Eighth Amendment is an area of the law that is often fact-intensive and can require balancing the rights of incarcerated citizens with the administrative judgment of prison officials. This appeal, however, is straightforward. Former inmate Anthony Mammana raises a challenge under the Eighth Amendment to his confinement in a chilled room with constant lighting, no bedding, and only paper-like clothing. The District Court dismissed Mammana's Amended Complaint, reasoning that Mammana had alleged only "uncomfortable" conditions. Because Mammana has adequately alleged a sufficiently serious deprivation under the Eighth Amendment, we will vacate and remand for further proceedings.
I. Background
Because the District Court dismissed Mammana's Amended Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6), we accept all well-pleaded allegations as true. Those allegations may be summarized as follows:
A. The Yellow Room
Plaintiff-appellant Anthony Mammana was an inmate confined at Allenwood Low Federal Correctional Institution, serving a seven-year sentence. During the fifth year of his sentence, Mammana began to feel "extreme illness after each meal" and visited the medical ward at Allenwood.
The psychologist, however, could not determine the cause of Mammana's discomfort and called the medical ward to advise them that Mammana would be returning there. However, Medical Assistant Taylor said she would refuse to re-admit Mammana to the medical ward if he returned, despite having never examined Mammana. Nonetheless, Mammana was escorted back to the medical ward, and after taking his blood pressure, Taylor "filed a false report,
However, upon learning the identity of his cellmate-who was known for "his deviate sexual behavior forced onto cellmates"-Mammana refused his assigned cell in administrative segregation.
In the Yellow Room, Mammana was stripped of his clothing and given only "paper like" coverings instead.
Mammana remained in the Yellow Room for four days. After he was released from the Yellow Room, a disciplinary hearing was held regarding Taylor's report; the hearing board eventually concluded "there was no basis" for her report and the "charges" against Mammana were "expunged."
B. Proceedings in the District Court
Mammana filed suit in the District Court. In his Amended Complaint, he set forth counts for malicious prosecution against the Federal Bureau of Prisons and Taylor, violation of due process against the Bureau, Taylor, and Barben, and cruel and unusual punishment in violation of his Eighth Amendment rights against the Bureau and Barben. Defendants moved to dismiss or for summary judgment, and Mammana withdrew all claims against the Bureau and Taylor. Parsing the Eighth Amendment claim, a magistrate judge recommended dismissal of Mammana's claims for constant lighting, lack of exercise, and deprivation of food; he recommended that Mammana's claim regarding the deprivation of warmth survive both dismissal and summary judgment.
Mammana objected to the magistrate's report and recommendation, and the District Court granted the motion to dismiss in its entirety, reasoning that Mammana had alleged only that the conditions of his confinement were "uncomfortabl[e]."
II. Legal Standard
Our review of the grant of a motion to dismiss under
III. Discussion
On appeal, Mammana contends that the District Court erred in dismissing his claim under the Eighth Amendment on the ground that the conditions of his confinement were merely uncomfortable. Because he has alleged not just merely uncomfortable conditions, but the deprivation of a specific human need, we agree with Mammana regarding this issue and will vacate the dismissal of his claim under the Eighth Amendment.
A. Applicable Law
The Eighth Amendment provides, "Excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted."
Wantonness, however, "does not have a fixed meaning but must be determined with 'due regard for differences in the kind of conduct against which an Eighth Amendment objection is lodged.' "
First, "the deprivation alleged must be, objectively, 'sufficiently serious,' "
Second, "a prison official must have a 'sufficiently culpable state of mind.' "
prison official must both know of and disregard an excessive risk to inmate health or safety. The ... element of deliberate indifference is subjective, not objective ... meaning that the official must actually be aware of the existence of the excessive risk; it is not sufficient that the official should have been aware.34
In other words, "the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference."
It is under this law that we analyze Mammana's allegations.
B. Analysis
The sole issue in this appeal is whether Mammana's allegations regarding the conditions of his confinement satisfy the first prong under the Eighth Amendment-an objective deprivation of sufficient seriousness. We conclude that Mammana has adequately alleged an excessive risk to inmate health and safety from the extreme and protracted deprivation of warmth and the ability to sleep presented in this case.
Mammana alleges that, for a continuous period over several days, he was denied clothing and bedding and subjected to low cell temperatures while his cell was constantly lit. "Conditions ... alone or in combination[ ] may deprive inmates of the minimal civilized measure of life's necessities."
Mammana has alleged such "mutually enforcing" conditions.
IV. Conclusion
For the foregoing reasons, we will vacate and remand for further proceedings.
Notes
JA 41.
JA 42.
JA 43.
JA 44.
Mammana v. Fed. Bureau of Prisons , No. 4:17-cv-00645,
The District Court had subject-matter jurisdiction under
Connelly v. Lane Constr. Corp. ,
Ashcroft v. Iqbal ,
U.S. Const. amend. VIII.
Wilson v. Seiter ,
Id. at 300,
Id. at 308,
Id. at 302,
Farmer v. Brennan ,
Rhodes ,
Farmer ,
Chavarriaga v. N.J. Dep't of Corr. ,
Farmer ,
Woloszyn v. County of Lawrence ,
Farmer ,
Mammana also argued in the District Court and on appeal that he was deprived of exercise and adequate meals. The Amended Complaint, however, contains no allegations regarding either of those claims, and they were properly dismissed.
Rhodes ,
Wilson ,
JA 44.
Wilson ,
Chavarriaga ,
JA 44.
JA 47.
Walker v. Schult ,
Keenan v. Hall ,
Wilson ,
