‘Horrifying’ Condiitons May Leave Prison Liable

     (CN) – A felon from upstate New York can pursue claims that federal officers kept him in a “horrifying,” overcrowded and unsanitary cell, the 2nd Circuit ruled.
     While incarcerated at Federal Correctional Institution Ray Brook, Ellis Walker claimed that he was confined to a six-man cell in violation of his rights against cruel and unusual punishment.
     The cell allegedly gave each man “less than 6-square feet [of] moving space,” and the beds were too narrow for Walker to lie down flat on his back. Such dimensions were especially hard on the 6’4, 255-pound Walker, according to the complaint.
     He said his cellmates included gang members and men of different races, which led to numerous fights and placed Walker “in a situation to kill or be killed.”
     Walker claimed that he was constantly kept awake by his cellmates staying up all night watching television and playing games. The sleep deprivation also allegedly left him unable to “work on a job 8 hours/day without hurting himself or someone else.”
     He said the cell was always unsanitary, the toilet needed cleaning “at least 15-20 times per day,” and that inmates were not given enough cleaning supplies to keep their living space clean.
     Ventilation in the six-man cell was additionally no different than it was for a two-man cell, making it extremely difficult to breathe in the summer, Walker claimed. In the winter, “the cell windows have ice two to four inches think on the inside of the six man cell,” according to the complaint, which Walker filed pro se.
     He described his experience of living in the cell as “horrifying.”
     Though a federal judge dismissed the action for failure to state a claim, the 2nd Circuit reversed last week.
     “Walker plausibly alleged that his conditions of confinement at FCI Ray Brook deprived him of the minimal civilized measure of life’s necessities and subjected him to unreasonable health and safety risks,” Judge Denny Chin wrote for a three-judge panel in Manhattan.
     The Eighth Amendment protects prisoners from exposure to extreme temperatures, denial of sleep or sanitary conditions, and exposure to life-threatening living situations, according to the judgment.
     Chin rejected the District Court’s hoolding “that Walker’s allegations of inadequate ventilation were insufficient because he did not provide any details about the temperatures in his cell.”
     “Such detailed allegations, however, are not required for a pro se complaint to survive a motion to dismiss,” he wrote.
     Also, “liberally construed, Walker’s complaint adequately alleged that defendants knew of and disregarded the excessive risks to his health and safety to which he was exposed at FCI Ray Brook,” the judgment said.

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