A six-woman and two-man federal jury found that Blain Steigerwalt, Unit Manager of the Special Management Unit at the State Correctional Institute at Camp Hill, violated Alfonzo Salley's constitutional right to the basic necessities of life.

Magistrate Judge Andrew Smyser presided over the two-day trial in his Harrisburg courtroom. The Eighth Amendment prohibition against cruel and unusual punishment requires that prison officials provide all inmates with the basic necessities of life. These include food, clothing, shelter and personal safety.

Salley alleged that he was denied food and basic items of sanitation and hygiene. Although the jury found that Salley's rights were violated, they awarded him One Dollar in nominal damages for the violation.

The P.I.L.P. was appointed to Mr. Salley's case by the U.S. Court of Appeals for the Third Circuit. Angus Love and Wendy Hess obtained a remand from the Circuit Court, finding that the lower court had dismissed Salley's pro se complaint prematurely.

Magistrate Smyser dismissed several claims via summary judgment. He allowed the basic necessities claim and a claim of failure to provide medical treatment for Salley's Hepatitis C condition to go to the jury. Defendant prevailed on the medical claim.

Salley was being held in the Special Management Unit which is a highly restrictive setting designed for disruptive inmates. The SMU is a supermaximum prison within a prison. Such units have attracted the scrutiny of international human rights groups such as Amnesty International and Human Rights Watch.

They have issued reports critical of the harsh regimes imposed on Supermax residents. The jury's decision suggests that the SMU needs to do more to protect the human rights of Salley and others who are subject to policies similar to those found deficient in the trial.

The case was tried by Angus Love, P.I.L.P. Executive Director, who was assisted by Jane Liu, a Sparer Fellow from the University of Pennsylvania Law School Public Interest Program run by Susan Feathers, Esquire. The defendants were represented by Laura Neal of the Pennsylvania DOC Chief Counsel's Office.