Grenning v. Miller-Stout, et al., No. 11-35579 (9th Cir. 2014)
Annotate this CasePlaintiff filed suit against defendants alleging that the continuous twenty-four-hour illumination of his cell violated the Eighth Amendment. The court reversed, concluding that there were material issues of fact remaining as to the brightness of the continuous lighting in plaintiff's cell, as to the effect on plaintiff of the continuous lighting, and as to whether the defendant officials were deliberately indifferent. Even if it were possible for a defendant to defeat an Eighth Amendment conditions of confinement claim at summary judgment by showing a legitimate penological interest, defendants have failed to make such a showing in this case. Because the district court did not consider the question of qualified immunity, the court left the issue for the district court to determine in the first instance. The court also remanded for the district court to consider the issue of filing fee deductions.
Court Description: Prisoner Civil Rights. The panel reversed the district court’s summary judgment and remanded in a 42 U.S.C. § 1983 action brought by a Washington state prisoner who alleged that the continuous twenty-four-hour illumination of his cell violated the Eighth Amendment. The panel held that there were material issues of fact as to (1) the brightness of the continuous lighting in plaintiff’s Special Management Unit cell, (2) the effect on plaintiff of the continuous lighting, and (3) whether the defendant officials were deliberately indifferent. The panel held that even if it were possible for a defendant to defeat an Eighth Amendment conditions of confinement claim at summary judgment by showing a legitimate penological interest, defendants failed to make such a showing in this case. The panel held that on remand the district court should consider the issue of qualified immunity in the first instance. The panel also determined that on remand, the district court should consider in the first instance plaintiff’s request that prison officials not garnish more than 20% of his prison account at a time in order to pay his court fees. Dissenting, Judge Rawlinson stated that the record supported affirming the grant of summary judgment in favor of the prison officials on the basis of qualified immunity because it would not be clear to a reasonable prison official that reliance on the proffered justifications for the use of constant illumination in the Special Management Unit would violate the Eighth Amendment.
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