Johnson v. Prentice, No. 18-3535 (7th Cir. 2022)
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Johnson entered state custody in 2007. His history of prison misconduct led to his transfer in 2013 to serve accumulated segregation (solitary confinement). Johnson suffers from serious mental illness, including depression and bipolar disorder, and he was on crisis watch nine times while in segregation. Mental health professionals regularly monitored his condition and treated him with medication, which was periodically adjusted. Johnson’s misconduct continued in segregation, especially when he refused to take his medication. Many of his violations were serious enough to trigger penalties of 30-90 days of no “yard” access.
Johnson sued under 42 U.S.C. 1983, alleging in his pro se complaint that the cumulative yard restrictions (totaling about three years, with 24 months consecutive) violated his Eighth Amendment right to be free from cruel and unusual punishment. He also complained of unsanitary conditions, poor ventilation, summertime heat in his cell, excessive noise, and inadequate mental health treatment. The district court granted the defendants summary judgment. Johnson obtained counsel and cited research on the harmful effects of solitary confinement. The Seventh Circuit affirmed. Johnson never sought relief for the time he spent in solitary confinement; he sued over his loss of yard access, unhealthy conditions in his cell, and his mental-health treatment. The record is entirely undeveloped on the issue of the effects of prolonged solitary confinement. Claims not raised in the district court are waived.
The court issued a subsequent related opinion or order on August 25, 2022.
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