Magazine article Corrections Forum

Prisoner Lighting Cases in the Courts

Magazine article Corrections Forum

Prisoner Lighting Cases in the Courts

Article excerpt

U.S. District Court Wills v. Terhune, 404 F.5upp.2d 1226 (E.D.Cal. 2005). A State prison inmate brought a § 1983 action alleging that constant illumination in the prison's Lights security housing unit constituted cruel and unusual punishment. The inmate moved for a preliminary injunction. The court denied the motion. The court held that constant illumination did not constitute an unsafe condition of confinement and that the defendants established a valid security purpose for the lighting. The inmate alleged that the low-wattage bulb prevented his sleep, but he conceded that it was not bright enough to read or write by. (CalifomiaState Prison, Corcoran)

U.S. District Court Maddox v. Berge, 473 F.Supp.2d 888 (W.D.Wis. 2007). A State prisoner brought a civil rights action under § 1983 against prison officials and employees, Lights alleging that his administrative confinement for participating in a riot violated his 8th and 14th Amendment rights. The court held that the allegation that the prisoner was subjected to 24-hour illumination stated a claim for violation of his 8th Amendment rights, although the prisoner did not allege that he suffered any adverse effects as a result of the lighting. The district court held that placement of the prisoner in administrative confinement, which subjected him to highly restricted non-face-to-face visits, lack of communication with other prisoners, nearly complete idleness in a cell that was constantly illuminated, lack of recreation, extremely limited out-ofcell time, and lack of access to any meaningful programming, was not clearly established as conduct that violated a prisoner's 8th Amendment rights, and therefore the warden and secretary of the corrections department had qualified immunity from the prisoner's damages suit under § 1983.

(Green Bay Correctional Institution, Wisconsin)

U. …

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