Access to Justice

Taylor v. Riojas, et al.

In Taylor v. Riojas, et al., the Supreme Court considered whether officers who confined an individual for six days in a cell where he was exposed to pervasive human waste are immune from being sued for violating the Eighth Amendment.

Case Summary

In 2013, Trent Taylor was placed in a cell in a prison psychiatric unit in Lubbock, Texas, so he could receive mental health care.  The cell, including the sink and faucet, was covered in human waste from a previous inhabitant.  Taylor was forced to live there for more than three days, despite his complaints to the officers in charge.  When Taylor was finally moved, he was placed in a cell with no toilet and no sink, only a clogged drain in the floor.  Because of the clogged drain and lack of a bed, Taylor was forced to sleep on the floor in a pool of overflowing sewage.  All told, Taylor was forced to live in these inhumane conditions for nearly a week, receiving none of the mental health treatment he needed.  A federal district court in Texas concluded that the officers in question had not violated Taylor’s constitutional rights because he had been held in the hazardous conditions “for only a matter of days.”  On appeal, the U.S. Court of Appeals for the Fifth Circuit held that while Taylor’s Eighth Amendment rights had been violated, he could not sue the officers because the right not to be subjected to such conditions for “so short” a period as six days was not clearly established.  Taylor then filed a petition for certiorari in the Supreme Court of the United States.

CAC filed an amicus brief in support of the certiorari petition, urging the Supreme Court to grant the petition, reverse the lower court’s decision, and to use this opportunity to reform its qualified immunity doctrine.  As our brief explained, qualified immunity in its present form has no grounding in the text or history of 42 U.S.C. § 1983.  Section 1983 was originally enacted by the Reconstruction Congress as part of a landmark civil rights law that was meant to deter constitutional violations by state and local officials by providing victims with a federal damages remedy.  While Congress intended Section 1983 to incorporate certain well-known immunities that were recognized by the common law at the time, today’s qualified immunity rules have no relationship to these historically established standards.  Instead, these rules often make it impossible to hold officials accountable for their constitutional violations.

Furthermore, our brief explained why today’s qualified immunity doctrine enables the very abuses Section 1983 was meant to deter.  After the Civil War, the Framers of the Fourteenth Amendment sought to expand the protections provided by the Bill of Rights, including the Eighth Amendment, to cover state governments, which were then flagrantly violating individual rights across the South.  Congress later passed Section 1983 to help people vindicate their constitutional rights by holding state and local officials financially accountable for their constitutional violations. Today, however, the Supreme Court’s qualified immunity doctrine allows those same types of violations to go unchecked, undermining the broad, remedial aim of the law that Congress passed.

The Supreme Court granted certiorari and issued a per curiam opinion vacating the Fifth Circuit’s decision and remanding the case for further proceedings. The Court held that the Fifth Circuit erred in granting qualified immunity to all of the officers involved. Because of the “particularly egregious” circumstances of Mr. Taylor’s confinement, the Court concluded that “any reasonable officer should have realized that Taylor’s conditions of confinement offended the Constitution.”

Case Timeline

  • June 1, 2020

    CAC files amicus curiae brief in support of petition for certiorari

    Sup. Ct. Amicus Br.
  • November 2, 2020

    The Supreme Court grants certiorari, vacates the Fifth Circuit’s decision and remands for further proceedings