Does Continuous Lighting Amount To Cruel And Unusual Punishment?

A Washington prisoner appealed the grant of summary judgment in favor of prison officials who placed him in a special unit where he was monitored every 30 minutes. In the unit, each single-inmate cell is illuminated with three four-foot-long fluorescent tubes. Two of the three may be turned off by the inmate, but one of them is kept on 24 hours a day. According to the prison, “continuous illumination allows officers to assess the baseline behavior of offenders to ensure they are not at risk of harming themselves or making an attempt to harm staff, cause property damage or incite problem behavior from other offenders.” On appeal, prison officials contended the prisoner’s claim is barred by the Prison Litigation Reform Act [PLRA; 42 U.S.C. § 1997e(e)], but the Ninth Circuit disagreed because that statute “applies only to claims for mental and emotional injury.” Here the prisoner argued the continuous lighting violated the Eighth and Fourteenth Amendments contending continuous lighting amounted to Cruel And Unusual Punishment. The appeals court reversed the grant of summary judgment. (Grenning v. Maggie Miller-Stout  (Ninth Cir.; January 16, 2014) 739 F.3d 1235.)