Court Battles

Supreme Court won’t hear case involving prison confinement and exercise

The Supreme Court in Washington, D.C., is seen on Tuesday, June 27, 2023.

The Supreme Court declined to hear a case regarding the alleged unfair treatment of an Illinois prisoner Monday, despite objections from three liberal justices.

Attorneys for inmate Michael Johnson argued the conditions of his confinement in a windowless room with only occasional trips to shower violated his constitutional right against cruel and unusual punishment.

A federal appeals court ruled the treatment did not fall under that clause.

Justice Kentanji Brown Jackson led fellow justices Sonia Sotomayor and Elena Kagan in dissent, arguing the appeals court failed to follow proper legal precedent in making its decision.

Jackson wrote that Johnson’s confinement was “unusually severe” compared to other solitary confinement conditions because he was also deprived of access to an outdoor exercise space, even for brief periods.

“Johnson spent nearly every hour of his existence in a windowless, perpetually lit cell about the size of a parking space,” she wrote. “His cell was poorly ventilated, resulting in unbearable heat and noxious odors. The space was also unsanitary, often caked with human waste.”

She described how Johnson was levied consecutive “yard restrictions” as punishment, banning him from use of the outdoor exercise area for three years straight after the 30- to 90-day infractions were stacked on each other.

“Thus, for three years, Johnson had no opportunity at all to stretch his limbs or breathe fresh air,” Jackson wrote.

Johnson also experienced deteriorating mental and physical health while confined in the cell, she argued, including suicidality and extreme physical fatigue.

“He suffered from hallucinations, excoriated his own flesh, urinated and defecated on himself, and smeared feces all over his body and cell,” Jackson wrote. “Johnson became suicidal and sometimes engaged in misconduct with the hope that prison guards would beat him to death.” 

“Worse still, Johnson’s dire physical condition led to further yard restrictions, as prison guards faulted him for being disruptive and having an unclean cell,” she continued.

The inmate was later confined to a mental health treatment facility where his condition improved, she said.

The 7th Circuit of Appeals reviewed Johnson’s case and ruled against him, saying that imposing individual “yard restrictions” doesn’t violate the cruel and unusual punishment clause. The court cited a previous case that justified a year of yard restrictions.

But Jackson argued that Johnson’s case is different because of the extreme length of the consecutive punishments, as well as his status as a mentally unstable inmate.

The appeals court “did not consider the impact of cumulative exercise deprivation on Johnson’s physical and mental health, or what was known to prison officials about the risks of such deprivation,” she wrote.

The justice said the court should have instead judged the case on the standard of whether prison officials showed “deliberate indifference” to Johnson’s health and safety, following a separate court present.

The Supreme Court does not provide an explanation when declining to take a case.