Wilson v. Seiter

Pearly Wilson (plaintiff) was a prisoner in an Ohio state prison. Wilson sued Richard Seiter and other prison officials (the prison officials) (defendants) in federal district court under 42 U.S.C. § 1983. Wilson alleged that the prison conditions were so inhumane that they qualified as cruel and unusual punishment in violation of the Eighth Amendment. Specifically, the complaint alleged that the prison was overcrowded and excessively noisy; had inadequate heating, cooling, and ventilation; had inadequate and unsanitary restrooms and dining operations; and housed prisoners with mentally and physically ill inmates. The district court granted summary judgment to the prison officials. Wilson appealed. The United States Court of Appeals for the Sixth Circuit applied a two-part test. The test’s first part was an objective inquiry into whether the alleged deprivations were so severe that they denied Wilson the minimal civilized measure of life’s necessities. The Sixth Circuit ruled that some of the allegations did not satisfy this test, and it dismissed them. The test’s second part was a subjective inquiry into whether the prison officials’ state of mind qualified as cruel. The Sixth Circuit found that the rest of Wilson’s claims did not satisfy this state-of-mind element because they fell short of alleging maliciousness, and it dismissed those claims, too. The United States Supreme Court granted certiorari.