Gates v. Cook.

• Position: Violation of United States Constitution. 8th Amendment

U.S. Appeals Court

LIGHTING

HYGIENE

TEMPERATURE

LAUNDRY

Gates v. Cook, 376 F.3d 323 (5th Cir. 2004). A death row prisoner brought a suit on behalf of himself and other prisoners confined to death row, alleging that certain conditions of confinement on death row violated the Eighth Amendment's prohibition against cruel and unusual punishment. The district court found that a number of conditions violated the Eighth Amendment and issued an injunction designed to alleviate the conditions. The defendants appealed. The appeals court affirmed in part and vacated in part. The court held that the prison's accreditation by a national correctional association (American Correctional Association) was not proof that the conditions of confinement did not violate the Eighth Amendment. The court noted that compliance with association standards could be a relevant consideration, but was not evidence of constitutionality. The court held that evidence supported findings that the probability of heat-related illness was extreme at the death row unit in which the class members were housed, and that corrections officials had displayed deliberate indifference. The court found that lighting in each death row cell was less than twenty foot-candles, in violation of the constitutional rights of the class members. Expert testimony was presented that lighting in the cells was grossly inadequate for the purposes of sanitation, personal hygiene and reading, and that these conditions contributed to further mental health deterioration. The court did not find a constitutional violation in the condition of the inmate laundry, which required inmates to wash their own clothes with bar soap. The court found that parts of the district court injunction that applied to sections of the death row unit that did not house class members exceeded the scope of the litigation and were...