A hell of a win for the inmate

This case is a hell of a win for the inmate, who won summary judgment against the jail on his claim that he was placed in isolation despite his mental health issues, in violation of the Eighth Amendment's prohibition against cruel and unusual punishment. That victory is now only partially gone, as the Court of Appeals finds the district court resolved disputed issues of fact in ruling in plaintiff's favor on the confinement issue. But the Court still finds in plaintiff's favor on another issue, holding that plaintiff's re-sentencing following the abolition of the death penalty in Connecticut was an unconstitutional bill of attainder. Plaintiff also wins an equal protection argument because he was treated differently than two other inmates who also committed heinous crimes.

The case is Reynolds v. Quiros, issued on March 11. Plaintiff was convicted of murdering a police officer and given the death sentence. But after the Connecticut Supreme Court ruled the death penalty was unconstitutional under the state constitution, plaintiff was re-sentenced to life imprisonment. The district court said the jail was deliberately indifferent to plaintiff's constitutional rights in placing him in confinement in light of his mental health condition. The court also held the jail violated due process in failing to provide plaintiff the minimal procedural protections in determining his reclassification following the state supreme court's death penalty ruling. For good measure, the district court said plaintiff was denied equal protection because two other inmates were able to live in the general population even though they had similar cases as plaintiff.

The state wins the Eighth Amendment appeal because the district court overlooked evidence that plaintiff was not actually placed in "solitary confinement" but went into the Special Circumstances Unit, which a jury may find is not quite solitary confinement. While true solitary confinement places the inmate in his cell 23 hours a day, where he eats his meals and the lights are always on, the Special Circumstances Unit allows plaintiff to exercise outside the cell, they could talk to inmates during that recreation period, and they can have social visits and phone calls. So a jury must determine whether this was really solitary confinement or not.

Plaintiff does win the equal protection argument, though. The two inmates who got more favorable treatment at the jail were comparable to plaintiff even though plaintiff was the only one who killed a police officer. The other two inmates also committed heinous crimes, however. One killed a sleeping man in his home as part of a contract killing, and the other killed a State Trooper during the commission of a burglary. Since plaintiff was classified differently than these inmates, his constitutional rights were violated. 

The final issue raised in this appeal is whether the state law that was enacted after State Supreme Court overturned the death penalty, sentencing inmates like plaintiff to life imprisonment, is an unconstitutional bill of attainder, which prohibits the government from determining guilt and inflicting punishment against people without a trial. The Court of Appeals (Cabranes and Kearse) rules it is not. This is a particularly obscure area of constitutional law. You almost never see bill of attainder cases. 

 

Plaintiff wins this argument because the law actually singles him and other death row inmates for punishment, it is punitive in placing inmates in administrative segregation, and the state legislature intended to punish plaintiff and other inmates in passing the law. And there was no judicial trial to mete out the new punishment.