Jeremy Lee Conlin felt that his mattress did not provide cervical, spinal, or lumbar support. Because he was a prisoner in a unit of the Texas Department of Criminal Justice (TDCJ), he could not take advantage of the many advertised bargains on quality mattresses. He instead filed a civil-rights lawsuit against TDCJ’s Director, Texas Correctional Industries, and another prison official. The lawsuit became case number 1:08-cv-00175 in the United States District Court for the Eastern District of Texas.
Magistrate Judge Keith F. Giblin concluded that the lawsuit was frivolous and should be dismissed. U.S. District Judge Ron Clark adopted Magistrate Giblin’s recommendation and dismissed the lawsuit on March 6, 2009. In a written order, Judge Clark concluded that Mr. Conlin’s “complaints regarding alleged deficiencies in his prison mattress simply do not rise to the level of a constitutional violation.”
Mr. Conlin apparently used some of his sleepless nights to prepare an appeal to the United States Court of Appeals for the Fifth Circuit (docket number 09-40286). In a written opinion that was released on October 16, 2009, a three-judge panel rejected the appeal and affirmed the District Court’s judgment. The panel found that Mr. Conlin’s complaints of mere discomfort were not enough to show a violation of the Eighth Amendment to the Constitution of the United States:
Conlin’s Eighth Amendment claim was properly dismissed because he did not allege facts establishing the objective component of a conditions-of-confinement claim. Although he argues that the loss of sleep he alleged demonstrated a deprivation of a basic human need, Conlin has not shown an egregious deprivation of a minimal life necessity that was so base or inhumane as to give rise to a constitutional violation.
Countless television, radio, and newspaper advertisements remind us of the important role that a comfortable mattress can play in our lives. The failure of Mr. Conlin’s lawsuit, however, demonstrates that the need for a quality mattress has not yet reached the level of a constitutional right.