Briaheen Thomas v. Tice

Summary

An inmate's Eighth Amendment conditions-of-confinement claim based on a nine-day dry cell placement failed because the PRC members lacked personal involvement in the specific deprivations. However, the inmate's claim based on the *duration* of that confinement survived summary judgment, as a genuine dispute existed whether the PRC had any penological justification to continue the dry cell placement after four days of negative x-rays and bowel movements. The PRC members were not entitled to qualified immunity on the duration claim because clearly established law requires at least *some* penological interest for administrative confinement. Key topics: Eighth Amendment, dry cell, administrative confinement, duration of confinement, penological justification, personal involvement, qualified immunity, summary judgment.

Holdings

1. The PRC members were not personally involved because there was no evidence that they had actual knowledge of the specific deprivations or were responsible for the conditions.
2. There is a genuine dispute of material fact as to whether there was a penological justification for continuing Thomas's confinement in the dry cell after June 4, 2015, so summary judgment was inappropriate.

Questions Presented

1. Whether the PRC members were personally involved in the conditions of Thomas's confinement in the dry cell so as to be liable under §1983.
2. Whether the PRC members violated Thomas's Eighth Amendment rights by continuing his confinement in the dry cell without penological justification.

Disposition

other