Lynn Hamlet v. Officer Hoxie

Petitioner Lynn Hamlet—an elderly man with visible open wounds on his ankles resulting from diabetes—suffered a life-threatening bacterial infection after Officer Brandon Hoxie trapped him in a backedup shower filled with another person’s feces, removed from his cell any method by which he could clean the excrement from his wounds, and barred him from showering for a week while human waste festered in his sores. Hamlet brought this suit under 42 U.S.C. § 1983, challenging Officer Hoxie’s conduct as violating the Eighth Amendment. The Eleventh Circuit held that Officer Hoxie was entitled to qualified immunity because there was no circuit precedent holding that the Eighth Amendment bars prison officials from forcing an incarcerated person to have gratuitous contact with human waste under these precise circumstances. The questions presented are: I. Whether it is “clearly established” for purposes of qualified immunity that the Eighth Amendment bars a prison official from forcing a person with diabetes and open wounds to endure prolonged and unnecessary exposure to feces. II. Whether the Court should overrule Procunier v. Navarette, 434 U.S. 555 (1978), and hold that qualified immunity under 42 U.S.C. § 1983 does not extend to a suit alleging that a prison guard subjected the plaintiff to unlawful conditions of confinement, because similar state officials were not immune from similar suits at common law.