Reed v. Zook — Prisoner Hygiene Items Claim Dismissed Under Eighth Amendment

Fri, 24 Apr 2026 01:46:48 +0000
Criminal Justice

The U.S. District Court for the Western District of Virginia dismissed pro se inmate Winston Najee Reed's 42 U.S.C. § 1983 civil rights action against Warden Zook et al. with prejudice. Reed alleged that prison officials violated his Eighth and First Amendment rights by denying him a hygiene pack—including a toothbrush, deodorant, and cleaning supplies—for eight days upon arrival at Wallens Ridge State Prison from May 20–28, 2025. Applying the Farmer two-part test for Eighth Amendment claims (objective seriousness and deliberate indifference), the court held that a temporary deprivation of toiletries does not constitute cruel and unusual punishment, citing prior circuit precedent holding that denial of hygiene products for comparable periods does not meet the threshold. The court further rejected Reed's First Amendment free exercise claim, finding that an eight-day deprivation of hygiene items does not impose a "substantial burden" on religious practice. The complaint was dismissed under 28 U.S.C. § 1997e(c)(1) for failure to state a cognizable claim.