Estelle v. Gamble

The Respondent, Gamble, an inmate in a state correctional facility, brought suit challenging the actions of the appellants, medical personnel at the facility, claiming they had subjected him to cruel and unusual punishment for inadequate treatment of a back injury suffered while he was undertaking prison work. After sustaining the injury, Gamble was seen by medical personnel on 17 occasions during a 3 month period. In treating his injury and other medical problems, they prescribed various medications and performed several tests. In order to review his capacity to return to work, Gamble was also subject to numerous prison disciplinary committee proceedings. Before lodging this complaint, Gamble was placed in solitary confinement and was refused treatment on several occasions.

The District Court dismissed the complaint for failure to state a claim upon which relief could be granted. The Court of Appeals held that the alleged insufficiency of the medical treatment required reinstatement of the complaint. This issue was reviewed by the Supreme Court.

The Court examined whether the prison medical personnel’s conduct constituted cruel and unusual punishment, constitutionally prohibited under the Eighth Amendment. The Court held that the alleged actions of the prison doctors did not constitute “deliberate indifference” to Gamble’s medical needs. The Court based its decision on claims which revealed that medical personnel saw Gamble on 17 occasions during a 3-month span. In those visits doctors diagnosed his injury as a lower back strain and treated it with bed rest, muscle relaxants, and pain relievers.

The Court held that “in order to state a cognizable claim, a prisoner must allege acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical needs.” It concluded that “deliberate indifference” amounts to the "unnecessary and wanton infliction of pain'” proscribed by the Eighth Amendment.

In response to Gamble’s claim that “more could have been done,” the Court held that the failure to perform an X-ray or to use additional diagnostic techniques did not constitute cruel and unusual punishment, but was, at most, medical malpractice for which state court was the proper forum. It added that “a complaint that a physician [was] . . . negligent in diagnosing or treating a medical condition [did] not become a constitutional violation merely because the victim was a prisoner.” However the Court noted that prisoners "must rely on prison authorities to treat [their] medical needs [and that] if the authorities fail to do so, those needs will not be met."

“These elementary principles establish the government's obligation to provide medical care for those whom it is punishing by incarceration. An inmate must rely on prison authorities to treat his medical needs; if the authorities fail to do so, those needs will not be met. In the worst cases, such a failure may actually produce physical ‘torture or a lingering death,’ In re Kemmler, supra, the evils of most immediate concern to the drafters of the Amendment. In less serious cases, denial of medical care may result in pain and suffering which no one suggests would serve any penological purpose. Cf. Gregg v. Georgia, supra, at 182-183 (joint opinion). The infliction of such unnecessary suffering is inconsistent with contemporary standards of decency as manifested in modern legislation codifying the common law view that ‘it is but just that the public be required to care for the prisoner, who cannot by reason of the deprivation of his liberty, care for himself.’ ” 429 U.S., pp. 103 – 104.

“This conclusion does not mean, however, that every claim by a prisoner that he has not received adequate medical treatment states a violation of the Eighth Amendment. An accident, although it may produce added anguish, is not on that basis alone to be characterized as wanton infliction of unnecessary pain. In Louisiana ex rel. Francis v. Resweber, 329 U. S. 459 (1947), for example, the Court concluded that it was not unconstitutional to force a prisoner to undergo a second effort to electrocute him after a mechanical malfunction had thwarted the first attempt. Writing for the plurality, Mr. Justice Reed reasoned that the second execution would not violate the Eighth Amendment because the first attempt was an ‘unforeseeable accident.’ Id., at 464. Mr. Justice Frankfurter's concurrence, based solely on the Due Process Clause of the Fourteenth Amendment, concluded that since the first attempt had failed because of ‘an innocent misadventure,’ id., at 470, the second would not be ‘ ‘repugnant to the conscience of mankind,’’ id., at 471, quoting Palko v. Connecticut, 302 U. S. 319, 323 (1937).” 429 U.S., p. 105.

“Similarly, in the medical context, an inadvertent failure to provide adequate medical care cannot be said to constitute ‘an unnecessary and wanton infliction of pain" or to be ‘repugnant to the conscience of mankind.’ Thus, a complaint that a physician has been negligent in diagnosing or treating a medical condition does not state a valid claim of medical mistreatment under the Eighth Amendment. Medical malpractice does not become a constitutional violation merely because the victim is a prisoner. In order to state a cognizable claim, a prisoner must allege acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical needs. It is only such indifference that can offend ‘evolving standards of decency’ in violation of the Eighth Amendment.” 429 U.S., pp. 105 - 106.