Federal Appeals Court revives inmate’s lawsuit over Wilson County jail conditions

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  • The 4th US Circuit of Appeals has revived an inmate's lawsuit alleging unsanitary conditions at the Wilson County Detention Center.
  • Kenneth Ray Jenkins filed suit against Sheriff Calvin Woodard. A federal trial judge had ruled in Woodard's favor in January 2022.
  • Jenkins argues that he was confined in a "rubber room" that had signs of waste, feces, and cockroaches. Jenkins contends that the unsanitary conditions caused him to contract a bacterial illness/

The 4th US Circuit Court of Appeals will allow a man to proceed with a lawsuit targeting unsanitary conditions at the Wilson County Detention Center. The unanimous decision reverses a trial judge’s order throwing out Kenneth Ray Jenkins’ case against Sheriff Calvin Woodard.

“The district court abused its discretion in denying Jenkins’s requests for appointment of counsel and additional time for discovery,” wrote Appeals Court Judge Roger Gregory. “Additionally, because the district court erred in denying Jenkins’s request for additional time for discovery, its pre-discovery summary judgment decision was premature.”

“We therefore reverse the court’s denials of Jenkins’s requests for appointment of counsel and additional time for discovery, vacate the court’s summary judgment decision on the merits, and remand this case for additional proceedings consistent with this opinion,” Gregory added. “We direct the district court to appoint counsel on remand to assist Jenkins with presenting his claims.”

Jenkins was detailed while awaiting trial in 2018. “According to Jenkins, while there, he faced unsanitary living conditions – including confinement in cells infested with feces – that caused him to contract a bacterial illness,” Gregory wrote.

The federal lawsuit asserts “conditions of confinement and deliberate indifference claims for violations of his rights guaranteed by the Fourteenth Amendment,” the 4th Circuit opinion continued.

The suit stems from events that took place within days of Jenkins’ arrival in jail. When authorities refused to give him medicine for his “depression, bipolar disorder, and anxiety disorder,” “an altercation ensued,” Gregory wrote. Jenkins ended up in solitary confinement, where he attempted suicide.

At the point, he was confined to a cell dubbed the “Rubber Room.” “The Rubber Room was unsanitary and had a persistent odor of waste and feces,” Gregory wrote. “It was also ‘infested with feces all over the room,’ including on the floor and ceiling.”

“While Jenkins was in the Rubber Room, officers fed him his food on the floor near feces, prohibited him from washing his hands, and told him to ‘eat with his hands’ the ‘best way’ he could,” the 4th Circuit opinion continued. “On at least one occasion, Jenkins’s food tray had roaches on it when officers gave it to him. On another, Jenkins alleges his tray was soiled by a green mold-like substance.”

Jenkins later developed bleeding problems and an infection. “In total, Jenkins suffered from heavy bleeding for eight months, and was denied medical attention for at least three of those months,” Gregory wrote.

US District Judge Terrence Boyle ruled for Woodard in January 2022. The Appeals Court panel disagreed with that decision.

“[I]t is obvious from the record before us that Jenkins lacks the ability to present his claims given his physical, mental, and intellectual limitations,” Gregory wrote. “Thus, even assuming the district court considered all the necessary factors, albeit without documenting its analysis, the court’s determination that this case does not present exceptional circumstances demonstrates a clear error of judgment under our prior decisions.”

Monday’s decision means that Jenkins will gain more time to conduct discovery in the lawsuit.

“Specifically, Jenkins noted that he could not access legal materials and evidence, has a low IQ, lacks general education and legal knowledge, has a history of severe mental health issues, and suffered from complications related to the COVID-19 pandemic at various points during the litigation,” Gregory wrote.

“Jenkins’s justifications readily explain his failure to conduct discovery,” the opinion continued. “And each of those barriers would have been remedied had the district court appointed counsel. Therefore, because the district court’s failure to appoint Jenkins counsel was an abuse of discretion and Jenkins’s lack of counsel denied him a meaningful opportunity to conduct discovery, the district court’s refusal to grant an extension of discovery was also an abuse of discretion.”

Judges James Wynn and Pamela Harris joined Gregory’s opinion.

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