Grenning v. Miller-Stout

In a 42 U.S.C. § 1983 action brought by a prisoner on the basis of continuous illumination of his or her cell, summary judgment is not appropriate where material issues of fact exist regarding the actual brightness of the constant illumination in the cell, the effects thereof, and whether the prison officials were deliberately indifferent to those effects.

Neil Grenning is an inmate at Airway Heights Corrections Center in Washington State (“Airway Heights”). Airway Heights contains a Special Management Unit (“SMU”) where the prison staff placed Grenning during the pending investigation of a fight that Grenning was allegedly involved in. The SMU contains single-inmate cells, and the lights are on 24 hours a day. Grenning stayed in the SMU for roughly 13 days. The separate cells within the SMU each have three four-foot-long fluorescent light tubes mounted on the ceiling. Two tubes can be switched on and off by the cell occupant, but the center tube remains constantly illuminated, albeit covered with a blue, light-diffusing sleeve. Grenning filed a complaint alleging that the constantly illuminated cell was an Eighth Amendment violation. He specifically alleged an inability to sleep, “recurring migraine headaches,” and an inability to distinguish whether it was night or day. Grenning also alleged pain and disorientation, but did not provide evidence of his seeking medical assistance. He did, however, submit a grievance informing prison officials of his inability to sleep and headaches. The district court, on behalf of the Defendant prison officials, granted summary judgment. Grenning appealed. After outlining the test to prove a prison-conditions-violation of the Eight Amendment, the Ninth Circuit held that there were, based on the record before the district court, material issues of fact as to the objective portion of that test, the actual brightness of the constant illumination in the SMU, and the effects thereof. Upon finding material issues of fact, the panel reversed the district court’s granting of summary judgment and remanded the action. On remand, the panel held that the district court should consider issues of qualified immunity and the prison officials’ garnishment of Grenning’s prison account to pay his court fees. REVERSED and REMANDED.