Florida corrections officials are seeking to dismiss a potential class-action lawsuit alleging unconstitutional conditions due to extreme heat at Dade Correctional Institution, a Miami-Dade County prison. The state argues that while conditions may be uncomfortable, they do not constitute cruel and unusual punishment.
The lawsuit, filed in October, names three Dade Correctional Institution inmates as plaintiffs and claims violations of the Eighth Amendment’s prohibition of cruel and unusual punishment, as well as violations of the Americans with Disabilities Act and the Rehabilitation Act. It specifically focuses on the impact of extreme heat on elderly inmates with pre-existing medical conditions, citing the lack of air conditioning in the prison’s dormitories.
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The lawsuit alleges that the Florida Department of Corrections (FDC) has “chosen to detain hundreds of elderly and disabled people…without taking any meaningful action to abate the risk caused by these extreme conditions.”
In a motion to dismiss filed Tuesday, lawyers for the FDC, Corrections Secretary Ricky Dixon, and Dade Correctional Institution Warden Francisco Acosta argued that the Eighth Amendment claim “fails because the facts do not give rise to a substantial risk of serious harm…nor demonstrate that Secretary Dixon or Warden Acosta has been deliberately indifferent.”
The motion further asserts that “the lack of air conditioning does not, by itself, pose a substantial risk of serious harm,” stating that the conditions must be “objectively ‘extreme’ enough to deny an inmate ‘the minimal civilized measure of life’s necessities.’” The motion argues the lawsuit’s allegations do not meet this standard, citing legal precedents and stating that the “Constitution does not mandate comfortable prisons.”
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The state also contends that Dixon and Acosta are taking reasonable steps to address heat-related risks within Dade Correctional Institution and other Florida prisons. They pointed to educational posters about heat dangers, staff instructions to provide cool water, directives to contact the duty warden for malfunctioning exhaust fans, and instances of officers bringing in ice during the summer. The motion also notes that the prison has undertaken repairs of exhaust fans.
However, the lawsuit maintains that inmates are subjected to “unbearable heat and abysmal air quality,” and that the defendants are aware of the substantial risk of serious injury posed by extreme heat, yet remain indifferent, failing to take adequate mitigation measures.
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The named plaintiffs in the lawsuit are Dwayne Wilson, 66, who suffers from hypertension, an enlarged prostate, and a burn scar that impairs his ability to sweat; Tyrone Harris, 54, who has hypertension and asthma; and Gary Wheeler, 65, who has chronic obstructive pulmonary disease. They are represented by attorneys from the Florida Justice Institute, who are seeking an injunction requiring corrections officials to implement a plan to mitigate the risks of extreme heat, potentially including the installation of air conditioning or other measures to maintain safe heat index levels in the dormitories.
The lawsuit, assigned to U.S. District Judge Kathleen Williams, follows increased scrutiny of prison heat conditions this year, including attention from state lawmakers. Senator Jennifer Bradley, whose district includes several prisons, acknowledged the issue of extreme heat and stated she had been working with Secretary Dixon to find mitigation strategies.
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