9. Conditions of confinement.

U.S. Appeals Court

ISOLATION

SEGREGATION

MEDICAL CARE

Jarriett v. Wilson, 414 F.3d 634 (6th Cir. 2005). A prisoner brought a civil rights action against prison officials under the Eighth Amendment, alleging deliberate indifference to his serious medical needs. The district court granted summary judgment for the defendants and the prisoner appealed. The appeals court affirmed, finding that the prisoner only had an unrecoverable "de minimis injury" for the purposes of his civil rights claim, which was subject to the provisions of the Prison Litigation Reform Act (PLRA). The court found that the officials' refusal to give the prisoner medical treatment was not objectively unreasonable. The prisoner had been put in a small strip cage and held there for 12 hours. He experienced swelling, pain and cramps in his legs as a result, but these injuries were not serious enough to mention to medical staff on the day of his release from the strip cage, or two days later. When he mentioned them two weeks later there were no medical findings. Prison staff had checked on the prisoner's assertions when he told them that he had a leg injury, before they placed him in the strip cage. The prisoner had been placed in the prison's segregation unit for fighting with another inmate. While in segregation, he went on a hunger strike to protest various prison conditions. His cellmate was required to eat his meal in a strip cage in the segregation unit so he would not pass any food to the prisoner during the hunger strike. The strip cage is a mesh steel cage with a small hole through which clothes or other items can be passed. When they later suspected that the prisoner was hiding food in his cell, they placed him in another strip cage next to his cellmate and ordered him to strip. (Trumbull Correctional Institution, Ohio)

U.S. Appeals Court

SMOKE

Larson v. Kempker, 414 F.3d 936 (8th Cir. 2005). An inmate brought a civil rights action against prison officials alleging that he was exposed to excessive cigarette smoke while he was confined. The district court awarded summary judgment in favor of the officials and the inmate appealed. The appeals court affirmed, finding that evidence was insufficient to establish that the inmate was exposed to unreasonable levels of environmental tobacco smoke (ETS). The court noted that the inmate's expert performed no scientific tests to establish the level of ETS in the inmate's cell, and the inmate did not present any other reliable...