Joseph Womble, an Oklahoma state prisoner, sued Warden Jerry Chrisman and Deputy Warden Tommy Sharp for conditions at the Mack Alford Correctional Center (MACC). Womble alleged that a sudden inmate influx in May 2014 led to severe overcrowding in the A-South unit, resulting in food rationing and unsanitary bathroom facilities.
The district court had granted summary judgment to the defendants on both claims. The Tenth Circuit affirmed the ruling on the nutrition claim, finding insufficient evidence that the food rationing created a substantial risk of serious harm or that the defendants acted with deliberate indifference.
However, the appellate court reversed the summary judgment on the facilities claim. The record contained evidence that 32 inmates housed in temporary bunks shared only two or three toilets, and that 132 inmates shared 11 showers.
Womble testified that toilets frequently overflowed, leaving feces on the floors. He also cited a lack of lighting in bathroom areas and clogged shower drains. The court noted that maintenance issues were often delayed or not fixed, exposing inmates to human waste.
Regarding the subjective component, Womble presented evidence that he informed the defendants about the exposure to feces. The defendants allegedly responded that nothing could be done and that it was a permanent situation.
The court rejected the defendants' reliance on work orders showing repairs, noting that inmates lacked a mechanism to submit written work orders and had to rely on verbal reports to staff.
The Tenth Circuit held that a reasonable jury could find the defendants knew about the unsanitary conditions and failed to take reasonable measures to abate them. The case is remanded for further proceedings.