Taylor v. Riojas

In September 2013, Trent Taylor, a Texas inmate in a psychiatric unit, was confined for six days in two shockingly unsanitary cells. The first cell was covered in massive amounts of feces, leading Taylor to refuse food and water for nearly four days out of fear of contamination. He was then moved to a frigidly cold cell lacking a bunk and toilet, with only a clogged floor drain that overflowed with raw sewage, forcing him to sleep naked in the waste. Taylor sued correctional officers under 42 U.S.C. § 1983, alleging an Eighth Amendment violation. The Fifth Circuit found a constitutional violation but granted qualified immunity, holding the law was not clearly established for a six-day confinement. The Supreme Court, in a per curiam decision, reversed, holding that no reasonable officer could have believed such conditions were constitutional.

The Supreme Court vacated the Fifth Circuit's judgment and remanded the case for further proceedings. In a 7-1 per curiam decision (Justice Thomas dissenting, Justice Barrett not participating), the Court held that the officers were not entitled to qualified immunity because any reasonable officer should have realized the conditions of confinement offended the Constitution.

Whether correctional officers were entitled to qualified immunity for confining an inmate in shockingly unsanitary cells for six days, specifically whether the law was 'clearly established' that such conditions violated the Eighth Amendment.

The decision is a rare civil rights victory that reaffirms the 'obviousness' standard, signaling to lower courts that a factually identical precedent is not required to overcome qualified immunity. It highlights the Supreme Court's willingness to police the excesses of qualified immunity doctrine, particularly in cases involving egregious constitutional violations, and has been cited in subsequent cases like McCoy v. Alamu.