Inmate Constitutional Rights and Exposure to Extreme Heat in Correctional Facilities

Climate scientists predict that a warming planet will affect every aspect of life. Correctional facilities are not immune from this phenomenon. During the summer months, some prisons have recorded indoor temperatures of up to 110 degrees Fahrenheit. Rising temperatures and severe heat waves, as a result of climate change, have led to a significant number of heat-related deaths and injuries among correctional populations in the United States. The current risk of death or illness in correctional facilities due to extreme heat remains a concern for correctional employees and health care personnel who are legally responsible for providing inmates their basic needs, including food, water, shelter, health, and safety. Inmates have resorted to federal courts for relief against heat-related conditions, arguing that exposure to extreme temperatures make their “conditions of confinement” unlivable, violating the Eighth Amendment’s prohibition against cruel and unusual punishment. This thesis analyzes cases from the U.S. Circuit Courts of Appeals and the U.S. District Courts, in which inmates challenged the constitutionality of their conditions of confinement in extremely hot facilities. The thesis applies inductive methods and analytic procedures of grounded theory to identify legal doctrines, concepts, representations, and themes of court litigation and case law concerning excessive heat in correctional facilities. By analyzing federal court decisions, this thesis examines the constitutionality of incarcerating inmates in extremely hot facilities and offers policy guidance to prison officials on mitigation efforts in heat-related conditions of confinement.