Jerry Cintron was sentenced for a drug violation and began serving a 10-year sentence at the Rhode Island Department of Corrections (RIDOC). He avoided using illicit drugs for the first three years of his incarceration, but in 2019, he overdosed on half a fentanyl-laced pill. He was hospitalized and revived with multiple doses of Narcan.
Paul Bibeault, an RIDOC investigator, interviewed Cintron about where the contraband pill came from. Cintron refused to cooperate and was threatened with confinement in the RIDOC high-security unit. After two RIDOC administrative disciplinary hearings, Cintron was adjudicated guilty and received a total of 55 days in solitary confinement.
During Cintron’s initial time in solitary, Bibeault interrogated him at least twice about the origin of the fentanyl. Cintron refused to cooperate during each attempt. Bibeault allegedly responded by threating him with additional prosecution, solitary confinement for a year, and told him, “I’m going to bury you alive.”
After three weeks in solitary, the RIDOC classification board reclassified Cintron from medium security to high security. He was transferred to the RIDOC’s high-security unit with the approval of Matthew Kettle, the RIDOC, Assistant Director of Institutions and Operations. Cintron had previously sent Kettle a letter requesting that he remain in medium security.
Following Cintron’s transfer to the high-security unit, over the course of the next 30 days, RIDOC determined that Cintron deserved additional punishment for drug trafficking (one-half a pill) and phone security violations. He received a total punishment of 450 days in solitary confinement. During his solitary confinement, Cintron was continually confined to his cell and deprived “of almost all human contact.” [1] Moreover, he was denied “access to [a] radio, television, an MP3 player, a desk, education, and programming,” [2] newspapers and a mirror. “Cintron spent his days with no more than ‘a bed and a toilet.’” [3]
Cintron deteriorated both physically and mentally during his protracted stay in solitary confinement, losing 70 lbs, engaging in self-harm behavior, and suffering from intrusive thoughts and severe anxiety. During his time in solitary, Cintron repeatedly asked various prison officials including Kettle, Jeffrey Aceto, Warden of the high-security unit and Lynne Corry, Deputy Warden for relief without success.
The Cintron lawsuit
Cintron sued Kettle, Aceto, Corry, Bibeault and other current and former RIDOC officials pursuant to 42 U.S.C. 1983 (federal civil rights statute), alleging that they violated his Eighth Amendment right to be free from cruel and unusual punishment. He claimed that “defendants deliberately responded indifferently to his suffering by continuing his punitive solitary confinement even as his physical and mental deterioration went untreated.” [4] The district court refused to dismiss Cintron’s Eighth Amendment claim and the defendants appealed.
The First Circuit Court of Appeals decision
The court noted that the RIDOC defendants assert that they are entitled to qualified immunity. The court explained that in order “[t]o defeat qualified immunity, Cintron must show both ‘(1) that [a defendant] violated a statutory or constitutional right, and (2) that the right was ‘clearly established’ at the time of the challenged conduct.’” [5]
The court instructed that for a prison official to violate the Eighth Amendment, proof of two requirements must be established. First, pursuant to the so-called “objective” requirement, the conduct of the prison official/s must be objectively sufficiently serious to establish that the victim inmate was subjected to “’a substantial risk of serious harm.’” [6] The court explained that the second requirement involves the subjective state of mind of the defendant and proof that “a prison official must have a sufficiently culpable state of mind.” [7] The court identified the necessary state of mind as “’one of deliberate indifference to inmate health or safety.’” [8]
The “objective” requirement/long-term solitary confinement
In making its determination that long term solitary confinement can present a serious risk of mental/physical harm to inmates, the court observed that long ago the Supreme Court recognized that solitary confinement may result in an inmate becoming violent, insane or suicidal. [9] The court also pointed to modern research that substantiates the opinion of the Supreme Court, e.g. “The Psychological Effects of Solitary Confinement: A Systematic Critique.” [10] Further, the court cited a Third Circuit opinion in which that court acknowledged, “the robust body of legal and scientific authority recognizing the devastating mental health consequences caused by long-term isolation.” [11]
The court likewise cited a Fourth Circuit opinion in which that court labeled conditions of incarceration that “deprive inmates of the basic human need for meaningful social interaction and positive environmental stimulation as posing a substantial risk of serious psychological and emotional harm.”
The objective requirement/deprivation of sleep
Cintron alleged that conditions during his period of solitary confinement continuously deprived him of his ability to sleep. He complained that the lights in his area of confinement glared overhead all day and night. Moreover, the loud banging of a door locking was repeated each half-hour for 24 hours a day.
The court observed that the Supreme Court has commented on sleep deprivation by stating, “It has been known since1500 at least that deprivation of sleep is the most effective torture.” [13] Moreover, the court pointed out that the “Amicus Center for Law, Brain & Behavior at Massachusetts General Hospital cites over a dozen academic studies documenting the harmful effects of sleep deprivation.” [14] As one writer succinctly summarizes, “‘[t]he brain starts to eat itself after chronic sleep deprivation.’” [15] The court further noted, “Indeed, several of our sister circuits have allowed Eighth Amendment claims to proceed where the plaintiffs alleged sleep-deprivation tactics akin to those allegedly deployed against Cintron.” [16]
The court found that Cintron’s allegations of long-term solitary confinement and deprivation of sleep were sufficient to support an Eighth Amendment requirement of “objective harm”, i.e., “that he was ‘incarcerated under conditions posing a substantial risk of serious harm.’” [17]
The subjective state of mind requirement/deliberate indifference standard
The court stated that Cintron must offer proof that the individual defendants had a blameworthy state of mind sufficient to meet the standard of deliberate indifference. The court explained that Cintron had to show that each individual defendant, “’had actual knowledge of impending harm [to Cintron], …and yet failed to take the steps that would have easily prevented that harm.’” [18] The court further explained that the actual knowledge requirement can be proven by concrete facts; by drawing inferences from actual facts; and by showing that the risk of harm to the inmate was simply obvious to individuals in prison leadership roles.
The decision of the First Circuit
With respect to RIDOC supervisory officials Aceto, Corry and Kettle, the court observed that each plausibly must have known based upon their supervisory status that RIDOC’S solitary confinement situation presented a risk of serious mental and physical harm to inmates confined there. Further the court observed that Cintron alleged that he and his social worker directly alerted Aceto and Corry of his deteriorating health situation and asked for early release from solitary confinement. These attempts were unsuccessful. He also alleged that he appealed to Kettle on several occasions for relief from solitary confinement without success.
The court observed that prison “officials can justify removing a prisoner from the general population to improve the safety of other inmates, [but] they cannot – in the face of that prisoner’s deterioration – perpetuate the kind of social, sensory, and sleep deprivation that Cintron alleges.” [19] The court ruled that with respect to defendants Aceto, Corry and Kettle, Cintron’s allegations, if proven true at trial, would establish an Eighth Amendment violation amounting to cruel and unusual punishment. The court further ruled that with respect to Cintron’s deteriorating conditions of continual solitary confinement and his prolonged periods of sleep deprivation, that the law was clearly established that violations of this nature violated the Eighth Amendment. Accordingly, the court refused to provide qualified immunity to the above defendants and ordered the case to proceed in the district court. [20]
Conclusion
This case clearly sets forth the legal requirements that a prison inmate must prove to establish an Eighth Amendment constitutional violation against prison officials pertaining to solitary confinement. The case likewise alerts prison authorities to the legal danger of placing inmates into solitary confinement for protracted periods of time and exposing them to continuous sleep deprivation.
Moreover, the case highlights the risk that prison officials take by ignoring inmate complaints (i.e., think deliberate indifference) relating to serious negative conditions faced while in solitary confinement. When inmates in solitary confinement complain about circumstances and conditions deleterious to their mental and physical health, prison officials should make a written record of the complaints and the steps taken to authenticate each complaint. The written record must include the reasonable and necessary steps followed to remedy the situation. Unaddressed complaints are likely to result in denial of qualified immunity in any lawsuits that may follow.
References
1. Cintron v. Bibeault, et.al., (No. 22 – 1716) (!st Cir. 8/5/25) (quoting) Wilkinson v. Austin, 545 U.S. 209, 214 (2005).
2. Cintron v. Bibeault, et.al., (No. 22 – 1716) (!st Cir. 8/5/25)
3. Id.
4. Id.
5. Id., (quoting) Ashcroft v. al-Kidd, 563 U.S. 731, 735 (2011).
6. Id., (quoting) Farmer v. Brennan, 511 U.S. 825, 834 (1994).
7. Id.
8. Id.
9. Id., See, In re Medley, 134 U. S. 160, 168 (1980).
10. Id., See, 47 Crime & Justice 365, 370-78, (2018).
11. Id., Palakovic v. Wetzel, 854 F.3d 209, 215 (3rd Cir. 2018).
12. Id., Porter v. Clarke, 923 F.3d 348, 368 (4th Cir. 2019).
13. Cintron v. Bibeault, supra note 1, (quoting), Ashcraft v. Tennessee, 322 U.S. 143, 150 n.6 (1944).
14. Id. See, e.g., Christian Benedict et al., Acute Sleep Deprivation Increases Serum Levels of Neuron-Specific Enolase (NSE) and S100 Calcium Binding Protein B (S-100B) in Healthy Young Men, 37 Sleep 195 (2014); Vinod Venkatraman et al., Sleep Deprivation Elevates Expectation of Gains and Attenuates Response to Losses Following Risky Decisions, 30 Sleep 603 (2007).
15. Id. See, Andy Coghlan, The Brain Starts to Eat Itself After Chronic Sleep Deprivation, NewScientist , (May 23, 2017),
16. Id. See, e.g. Walker v. Schult, 717 F.3d 119, 126 (2d Cir. 2013). The court also cited relevant cases in the third, fifth, seventh and ninth federal circuits.
17. Id. (quoting) Farmer v. Brennan, 511 U.S. 825, 834 (1994).
18. Id. (quoting) Zingg v. Groblewski, 907 F.3d 630, 635 (1st Cir. 2018).
19. Id.
20. The court dismissed the case against defendant Bibeault foe lack of sufficient evidence.
