Due Process for Civil Commitment Proceedings

Abstract

requiring proof that prison officials knew of, but disregarded, an excessive risk to the inmate. Accordingly, Mr. Clark was required to allege adequately that prison officials had a sufficiently culpable state of mind. Mr. Clark had asserted that the prison officials had known about his history of significant mental illness and yet had disregarded his pleas to leave the SHU, leaving him there for seven months and causing his mental health to deteriorate. The court concluded that Mr. Clark’s allegations, that prison officials were deliberately indifferent as to the effects of prolonged isolation on Mr. Clark’s already severely compromised mental health, were sufficient to raise a legitimate Eighth Amendment claim. Finally, the Third Circuit addressed the legitimacy of the district court’s ruling that no established law had been violated during the seven months Mr. Clark spent in the SHU. To meet this subjective standard, the prison officials must have had “fair warning” that their conduct violated the prisoner’s Eighth Amendment right. To address this question, the court reviewed its own precedents, relevant U.S. Supreme Court decisions, and multiple federal circuit court decisions with related fact patterns. In these decisions, the Third Circuit noted that the knowing infliction of serious psychological injury, by whatever means, had consistently grounded Eighth Amendment violation claims. The court also relied on Cmty. Legal Aid Soc’y Inc. v. Coupe, 2016 WL 1055741 (D. Del. 2016), a decision handed down by a Delaware district court when Mr. Clark had been in the SHU for two months. In this decision, the district court ruled that Commissioner Coupe’s alleged conduct of “placing mentally ill inmates in solitary confinement, without adequate mental health treatment and out-of-cell time, raised a viable constitutional claim” (Cmty Legal Aid, p 2). The court also cited a Delaware statute, which was in effect at the time of Mr. Clark’s solitary confinement, preventing courts from imposing a term of solitary confinement for more than three months. The court concluded that the law, along with other sources of notice, sufficiently “warned prison officials that their purported conduct was unlawful” (Clark , p 188). The Third Circuit held that the district court’s grant of qualified immunity was premature, reversed the district court’s order dismissing the conditions of confinement claim, and remanded the case for further proceedings. Discussion