Federal Appeals Court Says Texas Inmate’s Decade-Long Lawsuit Over Sleep Deprivation Can Keep Going
Is it cruel and unusual to subject an incarcerated person to sleep deprivation for years? That’s a question it has taken federal courts more than a decade to answer.
On March 22, the U.S. Court of Appeals for the 5th Circuit reinstated Texas inmate Michael Garrett’s 11-year-long-and-still-running lawsuit against the Texas Department of Criminal Justice, finding that a lower district court had repeatedly and incorrectly subjected him to a higher bar than it should have to prove that being afforded less than four hours of sleep a night violated his constitutional rights.
Garrett’s case is an extreme example of how long it takes and how difficult it is to prevail on an Eighth Amendment lawsuit, even on what should be a straightforward question.
Garrett first filed a lawsuit against the department in 2013 alleging that he and his fellow inmates inside his unit were given fewer than four hours of sleep a night—and only two and half hours of continuous sleep at most. Bedtime is at 10:30 p.m., followed by a 1 a.m. headcount, and then breakfast begins around 2 a.m.
Garrett argued the continual sleep deprivation posed a serious health risk and sought an injunction that would mandate a prison schedule with six hours per night designated for sleep.
A year later, a federal magistrate judge dismissed Garrett’s complaint for failure to state a claim, finding that he “has no constitutional right to a pre-determined number of hours of uninterrupted sleep each night,” and that to prevail, he “would have to establish that he has suffered a physical injury caused by the alleged sleep deprivation.”
However, the 5th Circuit reversed that decision, finding that sleep deprivation “could plausibly constitute a denial of the minimal civilized measure of life’s necessities.”
At a 2018 bench trial back in district court, a federal judge ruled against Garrett again, finding that he hadn’t directly connected his health problems—migraines, seizures, vertigo, and hy
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