Supreme Court Declines to Hear Case on Prison Conditions and Qualified Immunity

This decision leaves in place a lower court ruling that grants qualified immunity to prison officials who subjected an inmate to extreme cold, setting a precedent for how courts evaluate liability for prison staff in similar future cases.

• •The Supreme Court denied the petition for a writ of certiorari in Smith v. Kind.
• •The Seventh Circuit previously held that prison officials violated Antonio Smith's Eighth Amendment rights.
• •The Seventh Circuit granted the officers qualified immunity because it had not previously ruled on 'closely analogous facts' regarding temperature ranges of 25 to 57 degrees.
• •Antonio Smith was held naked in a control cell for 23 hours in late November in Green Bay, Wisconsin.
• •The cell had no mattress or bedding, and the vent blew air at outside temperatures.
• •Officers used pepper spray on Smith prior to his placement in the cell, despite his known asthma.
• •Smith requested clothing and bedding from Lieutenant Retzlaff, who did not provide them.
• •Justice Sotomayor, joined by Justices Kagan and Jackson, dissented from the denial of the petition.
• •The officers did not provide a penological justification for the conditions in the control cell.
• •The case originated from a hunger strike Smith began in October 2017.

Patterns POLISCOPE noticed across the record. These are observations to investigate, not conclusions.