Media Contact

Casira Copes
Communications Director

December 1, 2022

PHILADELPHIA, PA– On November 28th, the US Court of Appeals for the Third Circuit ruled in favor of the late Angelo Clark, who despite having serious and known mental health issues, was placed in solitary confinement by Department of Correction (DOC) officials for seven months while housed in a Delaware prison. 

The court ruled Clark successfully alleged that prison officials at the James T. Vaughn Correctional Center in Smyrna, DE, violated Clark’s Eighth Amendment right to be protected from cruel and unusual punishment. Importantly, the court also found officials were not protected by qualified immunity. After a lengthy appeal process, this decision marks a consequential victory not only for Clark’s family, who continue to serve as Mr. Clark’s personal representative after his passing in January 2022, but also for the rights of many other incarcerated individuals. 

During the months of his confinement Clark was held in an eight-foot by eleven-foot cell. The only human contact he experienced was the handoff of food through a four-inch slot in his door and one hour outside of his cell just three days per week. Clark repeatedly begged for his release and alleged that the confinement “increased hallucinations, paranoia, self-mutilation, sleeplessness and nightmares.” Mr. Clark’s complaint further alleged that prison officials were well-aware of the substantial risks of exacerbating his mental illnesses. The court ruled that Clark had sufficiently alleged conduct that no reasonable corrections officer could conclude was constitutionally permissible.

“For over 200 years, the U.S. Constitution has explicitly prohibited cruel and unusual punishment. It is unacceptable that despite this long standing precedent, we're still fighting against the cruelties of solitary confinement in 2022,” said Dwayne Bensing, ACLU-DE Legal Director. “Although Angelo Clark did not get to witness this victory, his fight for justice will help ensure that no other Delawarean has to live through the same horrific experience.”

Clark’s appeal was drafted by former ACLU-DE Legal Director Susan Burke and argued by Bensing on March 30th with assistance of co-counsel Chad Stover of Barnes & Thornburg and Michael Broadbent of Cozen O’Connor. “The Vaughn prison officials must be held accountable for the severe harm caused to Clark,” said Stover, “This decision is an important step forward in the effort to abolish the use of solitary confinement in Delaware prisons, especially for people with mental health issues.”

More information about this case, including case documents, is available here:

More information about the U.S. Court of Appeals for the Third Circuit is available here:

Find coverage of this case by WHYY here:

Find coverage of this case by Delaware Public Media here: