But “[c]ourts have stressed the duration of the exposure to the alleged unconstitutional conditions and the ‘totality of the circumstances' as critical to a finding of cruel and inhumane treatment.” Lloyd v. Barr, 2020 WL 5076065, at *3 (M.D. Pa. Aug. 27, 2020) (citations omitted). Therefore, “[w]hether the deprivation of food falls below [the constitutional] threshold depends on the duration of the deprivation.” Duran v. Merline, 923 F.Supp.2d 702, 720 (D.N.J. 2013) (quoting Berry v. Brady, 192 F.3d 504, 507 (5thCir. 1999).
He alleges that he was served spoiled food at a single meal, but "the denial of a single meal cannot lead to the denial of sufficient nutrition in a way which shocks the conscience and departs from minimal civilized standards of life's necessities." Lloyd v. Barr, No. 4:20-CV-1107, 2020 WL 5076065, at *4 (M.D. Pa. Aug. 27, 2020) (dismissing immigration detainee's claim). He alleges that his "unit" is cleaned only once per day, but this too does not constitute impermissible punishment.
"Courts have stressed the duration of the exposure to the alleged unconstitutional conditions and the 'totality of the circumstances' as critical to a finding of cruel and inhumane treatment." Lloyd v. Barr, No. 4:20-cv-1107, 2020 WL 5076065, at *3 (M.D. Pa. Aug. 27, 2020) (citation omitted).