Appeals panel rules in favor of former Delaware inmate

November 28, 2022 GMT

DOVER, Del. (AP) — A federal appeals court panel has ruled in favor of a former Delaware prison inmate who claimed he was deprived of his constitutional rights by being placed into solitary confinement for a long period despite his mental illness.

A three-judge panel ruled Monday that a federal district court judge wrongly dismissed a claim filed by Angelo Lee Clark challenging the conditions of his confinement. Clark died earlier this year at age 66 and is being represented in the appeal by a family member.

The federal district court judge in 2019 granted qualified immunity to Department of Correction officials and dismissed Clark’s claim alleging that his lengthy placement in solitary confinement violated his constitutional rights. The judge concluded that housing a mentally ill inmate in solitary confinement for long periods of time does not in itself violate a clearly established Eighth Amendment prohibition against cruel and unusual punishment.


The appeals panel concluded, however, that Clark had alleged that prison officials knew that the confinement conditions they imposed on him carried a risk of substantial harm and caused him to suffer debilitating pain that served no legitimate prison purpose.

“Because these allegations trigger established Eighth Amendment protection, we will reverse the grant of qualified immunity and remand for further proceedings,” Judge Luis Felipe Restrepo wrote for the panel.

According to court records, Clark, who was diagnosed with manic depression and paranoid schizophrenia, was housed in solitary confinement for fifteen days in 2015 and for seven months in 2016 before being moved to a psychiatric facility. The appeal involved only the time spent in solitary confinement in 2016.

Attorneys for Clark alleged that his placement in solitary confinement was in retaliation for his mental illness, loud voice, and minor rule infractions, and that his extended time in isolation worsened his mental illness. They argued among other things that holding a severely mentally ill inmate in solitary confinement when the harmful effects of such punishment are well known amounts to cruel and unusual punishment.

Clark’s attorneys alleged that prison officials kept Clark in isolation even though they knew of an American Correctional Association study on the effects of solitary confinement on seriously mentally ill inmates. That ACA study singled out the former warden at Delaware’s maximum-security prison, saying he was not open to change regarding the housing of mentally ill inmates.


“By alleging prison officials imposed solitary confinement for months, knowing the isolation carried a substantial risk of exacerbating his mental illnesses but keeping him there until he suffered serious harm, Clark alleged conduct that no reasonable corrections officer could conclude was constitutionally permissible,” the appeals panel said.

While declaring that the district judge’s grant of qualified immunity to prison officials was “premature,” the panel noted that the allegations in Clark’s complaint might be disproved in further proceedings and the conduct of prison officials found appropriate.