Taylor v. Riojas

What Happened

Trent Michael Taylor was an inmate in a Texas state prison. In September 2013, correctional officers confined him in a pair of cells that would be difficult to believe if they weren’t documented in the record.

The first cell was covered — nearly floor to ceiling — in “massive amounts” of feces. It was on the floor, the ceiling, the window, the walls, and even packed inside the water faucet. Fearing that his food and water would be contaminated, Taylor didn’t eat or drink for nearly four days.

Officers then moved Taylor to a second cell. This one was frigidly cold and equipped with only a clogged drain in the floor to dispose of bodily waste. Taylor held his bladder for over 24 hours, but eventually — involuntarily — relieved himself, causing the drain to overflow and raw sewage to spill across the floor. The cell had no bunk. Taylor had no clothing. He was left to sleep naked in sewage.

The cruelty wasn’t inadvertent. One officer, upon placing Taylor in the first cell, remarked to another that Taylor was “going to have a long weekend.” Another officer, putting Taylor in the second cell, told him he hoped Taylor would “f***ing freeze.”

Taylor sued the officers under § 1983, alleging violations of the Eighth Amendment. The Fifth Circuit agreed that the conditions violated the Constitution. But it granted the officers qualified immunity, reasoning that “the law wasn’t clearly established” that “prisoners couldn’t be housed in cells teeming with human waste” “for only six days.” The court cited what it called “ambiguity in the caselaw” about whether such a “short” period violated the Constitution.

What the Court Decided

The Supreme Court summarily reversed in a per curiam opinion — meaning the Court didn’t even bother with oral argument. The error was that obvious.

The Court held that “no reasonable correctional officer could have concluded that, under the extreme circumstances of this case, it was constitutionally permissible to house Taylor in such deplorably unsanitary conditions for such an extended period of time.” 592 U.S. at 9.

The Court relied squarely on Hope v. Pelzer, which held that a “general constitutional rule already identified in the decisional law may apply with obvious clarity to the specific conduct in question.” 536 U.S. at 741. The “obvious cruelty” inherent in certain “degrading and dangerous” conditions provides officers with fair notice that their conduct violates the Eighth Amendment. 536 U.S. at 745.

The Court found no evidence that the conditions were compelled by necessity or exigency. Nothing in the record suggested the conditions couldn’t have been mitigated in degree or duration. And the record showed that at least some officers were deliberately indifferent — as evidenced by their taunting remarks.

The Court distinguished a Fifth Circuit case the lower court had relied on — Davis v. Scott — which involved an inmate held for three days in a dirty cell and given cleaning supplies. That case was “too dissimilar, in terms of both conditions and duration of confinement, to create any doubt about the obviousness of Taylor’s right.” 592 U.S. at 10 n.2.

Justice Thomas dissented without opinion. Justice Alito concurred in the judgment but wrote separately to question why the Court granted certiorari on what he viewed as a case-specific factual question.

What It Means in Practice

Taylor v. Riojas is the most recent and vivid illustration of the Hope v. Pelzer principle: some government conduct is so obviously unconstitutional that officers don’t need a prior case with identical facts to have “fair warning.” You don’t need a case holding that feces-covered cells are unconstitutional to know that feces-covered cells are unconstitutional.

The decision is significant for several reasons:

• It limits the “clearly established” defense. Lower courts had been demanding increasingly particularized precedent before denying qualified immunity. Taylor pushes back: when the violation is obvious, general constitutional principles suffice.
• It signals the Court is watching. The summary reversal format sends a message to lower courts that granting qualified immunity in outrageous cases will be corrected — and publicly.
• It applies to conditions of confinement. Taylor is directly relevant to any case involving unsanitary, inhumane, or degrading jail or prison conditions, not just the specific facts of feces-covered cells.

Together with Hope, Taylor establishes that there is an “obvious case” category where qualified immunity cannot shield officers — even without on-point precedent.

How You Can Use It

Taylor is powerful ammunition for any case involving egregious government conduct:

• The “obvious case” argument. When the facts are extreme, argue that this is the kind of “obvious case” where Taylor and Hope apply. No reasonable officer could have thought this conduct was constitutional.
• Key quote: “No reasonable correctional officer could have concluded that, under the extreme circumstances of this case, it was constitutionally permissible to house Taylor in such deplorably unsanitary conditions for such an extended period of time.” 592 U.S. at 9.
• Pair with Hope v. Pelzer. These two cases work together. Hope established the principle; Taylor applied it to deny immunity in striking fashion.
• Push back on “show me an identical case.” When the defense demands a prior case with nearly identical facts, cite Taylor: the Supreme Court denied immunity even though no prior case had held that six days in a feces-covered cell was unconstitutional. The “obvious cruelty” was enough.
• Template: “Under Taylor v. Riojas, 592 U.S. 7 (2020), qualified immunity is unavailable when ‘no reasonable [officer] could have concluded’ that the conduct was constitutionally permissible. As in Taylor, the conduct here was so obviously [cruel/unreasonable/unconstitutional] that Defendant needed no prior case to know it was wrong.”

How It Can Be Used Against You

Defendants will try to confine Taylor to its extreme facts:

• “Your case isn’t that bad.” The defense will argue that Taylor applies only to truly shocking conditions — feces-covered cells, freezing temperatures, naked inmates in sewage. For less extreme conduct, they’ll insist on particularized precedent.
• “It was only temporary.” The defense may argue that the conditions, while unpleasant, were brief, were caused by emergency circumstances, or were beyond the officers’ control.
• “There was a legitimate reason.” Officers will claim security concerns, resource constraints, or institutional exigencies necessitated the conditions.

How to counter: Emphasize the principle, not just the facts. Taylor’s holding isn’t that feces-covered cells are unconstitutional (though they obviously are). The holding is that some conduct is so obviously wrong that officers are on notice without case-specific precedent. Document the conditions thoroughly — photographs, medical records, grievances, incident reports. And show, as Taylor did, that the conditions could have been mitigated but weren’t, revealing deliberate indifference rather than necessity.