Court Eyes Appeal Over Mentally Ill Inmate Put in Solitary in Delaware

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A federal appeals court is set to hear arguments in a lawsuit filed by a Delaware prison inmate who claimed he was deprived of his constitutional rights by being placed into solitary confinement because of his mental illness.

The appeals court will hear arguments Wednesday in the case of Angelo Lee Clark, who also claimed he was deprived of his rights to adequate medical care while in solitary confinement.

Attorneys for Clark filed the appeal after a federal court jury ruled in favor of Delaware prison officials last year. The jury found that prison officials did not violate Clark’s rights by putting him in solitary confinement or denying adequate medical care.

Clark died in January at the age of 66. A family member is acting as the appellant in the case.

According to court records, Clark was held at the James T. Vaughn Correctional Center from 2004 to 2019, when he was moved to a psychiatric facility.

While in prison, he was treated for serious mental illness, including manic depression, antisocial personality disorder and paranoid schizophrenia.

Clark was housed in solitary confinement for fifteen days in 2015 and for seven months in 2016.

Attorneys for Clark alleged that his placement in solitary confinement was in retaliation for his mental illness, loud voice, and minor rule infractions.

They argued among other things that holding a severely mentally ill inmate in solitary confinement when the harmful effects of such punishment are well known amounts to cruel and unusual punishment. Prison officials argued in a motion to dismiss that qualified immunity insulated them from liability for that claim. A trial court judge agreed but allowed the suit to proceed to the jury on other issues.