Unsanitary, Dangerous, Health-Threatening Conditions at Coffield Unit

The Conditions as described herein should be obvious to the trained eye of professional Correctional Staff. These conditions are longstanding and pervasive. I respectfully request to not be retaliated against for the exercise of my constitutional rights. It is well noted in every Circuit and the Supreme Court that "prison officials may not retaliate against or harass an inmate because of his exercise of his First Amendment right to seek redress of grievance."

I. Unsanitary Conditions in Chowhall

The conditions in the chowhall are unsanitary. The spoons, trays and cups are not properly washed and sanitized before and after each use. The trays often have standing water in them, the spoons are greasy and often have food residue on them. The chowhall floor is filthy and there are puddles of standing water on the floor on a regular basis. The staff and inmates who are serving food do not wear gloves. The tables are not properly wiped and sanitized.

The chowhall is known to be infested by cockroaches, mice and birds. The birds are known to eat the cornbread out of the pans in the baking area, and to defecate on the cornbread. It is believed that security cameras in the baking and kitchen areas confirm this. The floor drains in the cooking area are known to back up with raw sewage.

These unsanitary conditions, individually and collectively, may be conducive to the spread of food borne illnesses; these conditions pose a threat to the health of inmates at the Coffield Unit.

II. Sleep Deprivation

The policies of TDCJ/Coffield Unit contribute to and cause the sleep deprivation of inmates. Sleep is recognized as a basic human need. TDCJ's system-wide policy of having Correctional Staff conduct late-night bed-bunk counts deliberately causes sleep deprivation.

Between 11:00 PM and 2:00 AM, inmates are awakened by a Correctional Officer, and are asked to present their Prison Identification Card, or to recite their number.

Furthermore, several times throughout the night, the guards in the Control Picket, or "Rotunda," are blaring announcements on the intercom loudspeakers. This disturbs inmates from their sleep.

Finally, Coffield begins feeding breakfast between 2:00 AM and 2:30 AM. Feeding time may run until 4:00 AM. If an inmate goes to have breakfast they may lose an hour of sleep, or possibly more. They are forced by this ridiculous schedule to choose between sleep or food.

Then between 4:00 AM and 5:00 AM, Coffield begins showering. Thus causing the loss of at least another hour of sleep.

Therefore, because of the bed-bunk counts, loudspeaker blaring, breakfast and showering schedules it is near impossible to get even 4 hours of uninterrupted sleep per night. This sleep deprivation poses a serious risk of physical and psychological harm to inmates.

III. Overcrowding

The cells at the Coffield Unit are too small for double occupancy. The cells were only designed for single occupancy. Hence it follows that the day-rooms are overcrowded and must serve double the number of inmates for which they were designed.

Inmates at Coffield in the main building are confronted with the reality that overcrowding is omnipresent within the confines of the prison. This overcrowding has an adverse effect on all the day-to-day operations of the prison.

The cells at the Coffield Unit and the other older model units have an area of only forty-five square feet, with only twenty-one and a half square feet of usable floor space. So cramped are such cells, that two persons standing, must squeeze by each other in order to pass. This cramped closeness of confined persons causes tension and sometimes leads to fights and violence.

These cells are not equipped with a table or bench to sit on. The top bunks are not equipped with a ladder or steps to assist inmates in climbing up and down. This is an obvious safety hazard.

Some of the obvious psychological effects of such overcrowded confinement are, i.e. the spread of disease, the enhancement of stress, tension, hostility, depression and physical and psychological deterioration.

These negative effects due to overcrowding run counter to the process of rehabilitation, and are the cause of serious behavioral problems.

IV. Day-rooms/Ingress-Egress

The day-rooms are overcrowded, they lack the necessary area required for the number of inmates they house; they also lack sufficient seating. The bathroom facilities in the day-rooms are inadequate: there is only one urinal, one sink and NO toilet.

Hourly ingress and egress moves are not conducted. Per TDCJ Policy, these moves are to be done hourly. However, often times inmates are trapped in cramped, overcrowded and noisy day-rooms without adequate bathroom facilities for 2 or 3 hours at a time without being given the opportunity to go to their cell.

The day-room's whole back wall window panels do not have tint of shade to guard against the hot bright sun. The sun is magnified by the glass panels and shines directly into the day-room, blinding inmates and turning the day-room into a very hot and muggy torture chamber. There are no fans to circulate the air. There are no screens on the windows to keep mosquitoes out. Mosquitoes are carriers of disease.

V. Lack or Regular Exercise/Outdoor Exercise

Inmates at the Coffield Unit on P3 & P4 are not afforded regular opportunities for exercise, and they are not afforded regular/any opportunities for outdoor exercise, and access to fresh air and sunshine.

Regular exercise, fresh air and sunshine are basic human needs. They are necessary for maintaining one's physical and psychological health.

By contrast, inmates in medium custody are afforded regular outdoor exercise during the afternoon. Likewise inmates in P5 and P6 receive outdoor exercise daily. Only inmates in P3-P4 are singled out and denied outdoor exercise.

Furthermore, per TDCJ Policy, there is supposed to be a recreation schedule posted for inmates to consult. There is no such schedule posted in the cell blocks at Coffield.

VI. Lack of Exercise Opportunities for Inmates with Chronic Medical Problems/Disabilities and Aging Inmates

There are no Exercise Programs for older inmates (late forties and older) or for inmates with disabilities or other medical conditions.

When gym, a.k.a. "indoor recreation" is called, it is extremely overcrowded and it is difficult to get any exercise at all. All Coffield offers is basketball, handball and an overcrowded universal weight machine.

These recreational policies systematically discriminate against and deprive older inmates and inmates with health problems and disabilities from being able to get any exercise at all.

The inmates do not even have an opportunity to walk or jog for thirty minutes to an hour, 3 or 4 times a week.

Inmates who are older, as well as inmates who suffer from chronic health conditions/disabilities form a recognizable class of inmates who are protected under the "Equal Protection Clause", and also the "Americans with a Disability Act".

The discriminatory conduct perpetrated by TDCJ/Coffield Unit are actionable in Federal Court. Furthermore, the conditions described herein are in violation of the Eighth Amendment to the Constitution, and constitute Cruel and Unusual punishments.

VII. Conclusion

It is obvious that the Conditions of Confinement deprive inmates of the minimal civilized measures of life's necessities, and subjects them to unreasonable health and safety risks.

These conditions described herein are longstanding and pervasive; they do pose a serious risk of harm to all inmates at the Coffied Unit.