Smith v. Kind

Summary

The Court denied certiorari without explaining its decision or resolving the merits of Smith’s Eighth Amendment and qualified-immunity claims. Justice Sotomayor, joined by Justices Kagan and Jackson, dissented and would have summarily reversed the Seventh Circuit’s grant of qualified immunity. She reasoned that existing precedent clearly established that officers could not intentionally confine a prisoner naked in freezing conditions for 23 hours without clothing, bedding, or another means of keeping warm. She criticized the Seventh Circuit’s demand for closely matching temperatures and durations and the Court’s perceived asymmetry in intervening in qualified-immunity cases.