The Origin of Prisoner's Rights: Estelle v. Gamble 429 U.S. 97; 75-929 (1976)
Estelle v. Gamble 429 U.S. 97; 75-929 (1976)
Category: Medical treatment.
Holding: 8-1 for the defendant/petitioner.
429 US 97; 75-929
This case revolved around a prisoner, J.W. Gamble, in the Texas prison system. Late in 1973, while working in a textile mile, a large bale of cotton-over five hundred pounds in fact-fell right on top of him. Due to the incident, he received numerous injuries including substantial damage to his lower back. Initially, physicians at the prison tried to determine if he herniated a disc but decided that he did not. Therefore, they gave Gamble some medication and sent him back to work. Unfortunately, the pain did not subside and he rebuffed repeated demands for him to return to work. Prison staff decided to reprimand him for his intransigence and put him in solitary confinement. Later, Gamble realized that his condition had worsened and so he decided to file a pro se complaint asserting he had been subjected to cruel and unusual punishment. The district court dismissed his case but on appeal the Fifth Circuit Court of Appeals reversed this dismissal. In its decision, the Fifth Circuit noted the lack of treatment and diagnosis that the prison gave the prisoner and that the solitary confinement further compounded his problems. The Texas government appealed this decision to the Supreme Court and was granted certiorari.
First, did Gamble state a claim upon which relief could be granted or at least advance a constitutional issue when arguing that he was exposed to cruel and unusual punishment?
Second, was the Fifth Circuit wrong in reversing the lower court’s dismissal of Gamble’s case?
The Court’s analysis of this case dove deep into the facts and the plaintiff’s specific complaints. At the onset, it noted that Gamble actually received medical attention more than a dozen times while in prison over just a few months. Further, it stated that if any care given to him was inadequate it may have just been inadvertent or merely negligent-a determination that should be made by his treating medical professionals. However, it did go on to set a standard for the requisite medical treatment due to prisoners. The Court ruled that prisons subject prisoners to cruel or unusual punishment if they act with deliberate indifference to the prisoner’s medical needs. It concluded as much when it said the following: “We therefore conclude that deliberate indifference to serious medical needs of prisoners constitutes the ‘unnecessary and wanton infliction of pain…’”
To the first issue, the court found that Gamble did not state a claim upon which relief could granted or advance a constitutional issue because the Texas government afforded him medical care, despite however inadvertent or negligent it was.
To the second issue, the Court ruled that the Fifth Circuit was wrong in reversing the lower court’s dismissal of Gamble’s case because the form of medical treatment was a matter left to the treating medical professionals that could not rise to the level of cruel or unusual punishment.
This case broke down 8 to 1. The majority consisted of Burger, Brennan, Stewart, White, Marshall, Blackmun, Powell, and Rehnquist. John Paul Stevens was the lone dissenter.
This is a seminal case for prisoners’ rights and the obligations of prison systems throughout the country. It declares that courts cannot act with deliberate indifference when the health of inmates is at stake. Note, this rule was extended in Helling v. McKinney to require plaintiffs to illustrate how science and culture would not tolerate the conditions that the particular prisoner was being subjected to.