Lawsuit Alleging Denial of Warmth and Sufficient Sleep States Eighth Amendment Claim
by David M. Reutter
On August 14, 2019, the Third Circuit Court of Appeals reversed the dismissal of a federal prisoner’s civil rights complaint that alleged he was confined in a cold cell with constant lighting, no bedding and only paper-like clothing.
FCI Allenwood Low prisoner Anthony Mammana appealed after a Pennsylvania district court granted the defendants’ motion to dismiss his Eighth Amendment claims.
After Medical Assistant Taylor “filed a false report” accusing Mammana of “harassment, stalking, and interference with the performance of his duties,” Mammana was taken to the segregation unit.
He refused a cell assignment with a prisoner known for “his deviate sexual behavior forced onto cellmates.” Lt. Barben then ordered Mammana placed in the “Yellow Room,” which was regarded by prisoners as a “mental and physical abuse room.”
Due to the combined clothing restrictions, cold temperature, constant light and “extremely thin mattress,” Mammana “could hardly sleep and would wake up frequently shivering when he did fall asleep.” He remained in the Yellow Room for four days and was released after a disciplinary hearing found “there was no basis” for Taylor’s report. The charges against him were expunged.
In response to his lawsuit, the Bureau of Prison defendants moved to dismiss. The district court granted their motion, finding that Mammana had alleged only that the conditions of his confinement were uncomfortable. A timely appeal ensued and the Third Circuit reversed.
The Court of Appeals found Mammana had “adequately alleged an excessive risk to inmate health and safety from the extreme and protracted deprivation of warmth and the ability to sleep....” It noted the Supreme Court has explained that “a low cell temperature at night with a failure to issue blankets” can constitute an unconstitutional deprivation. The same applies to depriving a prisoner of clothing without a “legitimate penological reason.”
The appellate court also wrote that “sleep is critical to human existence, and conditions that prevent sleep have been found to violate the Eighth Amendment.” Additionally, bright, constant illumination that causes “grave sleeping problems and other mental and psychological problems” can be unconstitutional.
The Third Circuit found that Mammana’s claims reflected more than a mere denial of a “comfortable prison”; rather, he alleged the denial of “the minimum and civilized measures of life’s necessities.” Accordingly, the district court’s order was vacated and the case remanded, where Mammana is now represented by counsel. See: Mammana v. Federal Bureau of Prisons, 934 F.3d 368 (3d. Cir. 2019).
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Related legal case
Mammana v. Federal Bureau of Prisons
| Year | 2019 |
|---|---|
| Cite | 934 F.3d 368 (3d. Cir. 2019) |
| Level | Court of Appeals |
| Appeals Court Edition | F.3d |