In re Williams

Robert Williams (defendant) was incarcerated in a Washington state prison following his conviction for a violent crime. While sentenced, at age 77, Williams had a stroke that impaired his mobility. Afterward, Williams relied on human aides and a wheelchair to move and perform daily tasks. Williams also had diabetes and hypertension. At that time, Williams was housed with three other inmates in a cell that did not have a sink or a toilet. If Williams needed to go to the bathroom, he had to request assistance from prison officials to push him to a wheelchair-accessible restroom. Williams frequently had to wait long periods of time for this assistance, which resulted in him urinating on himself or in bottles with no way to clean himself properly. Around this same time, the COVID-19 pandemic began. Williams asked the Washington Department of Corrections (DOC) for an extraordinary medical placement, asking to be released to house arrest at his sister’s home in Florida to limit his potential exposure to the potentially fatal COVID virus, arguing that he was at especially high risk given his health conditions and race (Black). The DOC denied his request. The now 78-year-old Williams filed a petition with the state courts, alleging that his confinement conditions violated the prohibition on cruel punishment in the Washington Constitution and the prohibition on cruel and unusual punishment in the Eighth Amendment to the United States Constitution. Prison officials argued that the confinement conditions were not cruel because they served the penological goals of retribution, deterrence, incapacitation, and rehabilitation. The Washington Court of Appeals denied the petition. The Washington Supreme Court agreed to review the matter. After a hearing, the court ordered the DOC to either correct the confinement conditions or release Williams and then issued an opinion explaining its reasoning.