Michael Garrett, a felon serving a life sentence since 1994, has committed his time in prison to completing online law classes as he battles the Texas prison system over sleep deprivation.
Garrett, 54, sued the Texas Department of Criminal Justice (TDCJ) more than a decade ago while he was housed at McConnell Unit in South Texas, claiming prison conditions amount to “cruel and unusual punishment” and violate his Eighth Amendment rights.
The plaintiff, who has been convicted of aggravated robbery, aggravated sexual assault, and theft, claims that due to frequent security checks in the prison, he often gets only around four hours of sleep per night, as reported by Texas Observer.
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In his 9-by-5-foot cell shared with another inmate, bedtime starts at 10:30 pm, but he experiences disruptions like bright hallway lights, slamming doors, and noise from neighboring cells, making it difficult to rest.
Inmates like Garrett face disrupted sleep patterns due to mandatory headcounts at 1 am and 2 am, to which inmates are expected to respond verbally, as reported by the Mail. They are compelled to wake up once again at 2 am for breakfast with the day interrupted by programming, check-ins, and appointments.
Aside from the noise from fellow prisoners and guards throughout the day, Garrett says the moment he attempts to take a nap, the sleep schedule is disrupted with another head count. Due to frequent interruptions during the night, Garrett says he is now suffering from migraines, high blood pressure, and seizures.
To address this, he started pursuing online law classes to advocate for a change in the prison schedule, intending to secure a guaranteed six hours of uninterrupted sleep each night.
Garrett filed his initial lawsuit against the TDCJ in 2013 and represented himself with a strong grasp of legal proceedings. Federal district court judges ruled against Garrett three times, saying that there was no constitutional right to sleep in prison and that he failed to prove his lack of sleep directly caused his medical conditions. Despite initial setbacks and the rulings against him by federal district court judges, Garrett’s persistence paid off when he won three appeals in higher court, the conservative Fifth Circuit.
His impressive legal knowledge has earned praise from seasoned attorneys. “He knows the rules. He knows the hurdles that lawyers face. He’s patient, and he is in it for the long term,” criminal defense attorney, Naomi Howard, told the Texas Observer. “I mean, the man survived the Fifth Circuit without any help from me.”
Garrett has conducted extensive legal research, writing, and filings from his prison cell and the prison’s law library throughout his lawsuit against the TDCJ. Howard started working with Garrett before his second civil trial, pro bono.
It is yet to be known what will happen with Garrett’s case against the prison system. After the Fifth Circuit ruled in favor of Garrett in March, the state has not revealed whether it plans to continue to appeal, as reported by the Texas Observer.
“I knew [the suit] was going to be a long road. But I didn’t think it was going to be this long,” said felon Garrett, who is now housed in the Estelle Unit in Huntsville.
