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Estelle v. Gamble
Seal of the United States Supreme Court.svg
Argued October 5, 1976
Decided November 30, 1976
Full case name Estelle, Corrections Director, et al. v. J. W. Gamble
Citations 429 U.S. 97 (more)
97 S. Ct. 285; 50 L. Ed. 2d 251; 1976 U.S. LEXIS 175
Holding
In order to state a cognizable Section 1983 claim for a violation of Eighth Amendment rights, a prisoner must allege acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical needs, and that medical malpractice did not rise to the level of "cruel and unusual punishment" simply because the victim was a prisoner.
Court membership
Case opinions
Majority Marshall, joined by Burger, Brennan, Stewart, White, Powell, Rehnquist
Concurrence Blackmun
Dissent Stevens

Estelle v. Gamble, 429 U.S. 97 (1976), was a case in which the Supreme Court of the United States established the standard for a prisoner to claim a violation of Eighth Amendment rights under 42 U.S.C. § 1983. Specifically, the Court held that a prisoner must allege acts or omissions sufficiently harmful to evidence deliberate indifference to serious medical needs.

Background[edit]

History[edit]

The Eighth Amendment to the United States Constitution bars cruel and unusual punishments. Originally, the Eighth Amendment was simply interpreted as barring torture and other extreme forms of punishment, similar to the English Bill of Rights 1689 that inspired it.[1] However, the Supreme Court began interpreting the Amendment more broadly in the 20th century.[2] For example, the Court announced in 1958 in Trop v. Dulles that "[t]he basic concept underlying the Eighth Amendment is nothing less than the dignity of man" and that "[t]he Amendment must draw its meaning from the evolving standards of decency that mark the progress of a maturing society."[3] In Robinson v. California, the Court ruled that the Eighth Amendment applied to the states through the Fourteenth Amendment.

Gamble was a state prisoner in Texas. He injured his back "on November 9, 1973, when a 600-pound bale of cotton fell on him during a prison work assignment at the prison textile mill in Huntsville, Texas."[4] Gamble worked for a few more hours before requesting and being granted a pass to the hospital.[5] He returned to the medical unit several times throughout November 1973 where the staff diagnosed his injury as a lower back strain and they prescribed him pain medication.[6] On December 3rd, the medical staff concluded that Gamble could return to light work but he refused, claiming he was still in too much pain.[7] He was placed in administrative segregation and then brought before a disciplinary committee a few days later who directed him to be examined by a second doctor. That doctor prescribed pain medication and pills for high blood pressure, and Gamble saw him throughout December 1973. [8]

Prison officers repeatedly asked Gamble to return to work in January 1974 and, when he refused claiming he was still in pain, threatened to send him to the prison work farm.[9] The prison medical staff continued to reissue his pain and blood pressure pills in January 1974.[10] Gamble was brought before the disciplinary committee again on January 31st for his failure to work. They found him guilty and placed him in solitary confinement.[11] A few days into solitary confinement he asked to see a doctor, complaining of chest pains and 'blank outs.'[12] Although that request was eventually granted, the guards refused several of his subsequent requests to see a doctor in early February.[13] Gamble ultimately signed his complaint in this case on February 11, 1974.

District court[edit]

Gamble filed his original, 24-page, handwritten complaint pro se in the United States District Court for the Southern District of Texas. His complaint—based on 28 U.S.C. § 2201, 28 U.S.C. § 2202, and the Eighth Amendment via 42 U.S.C. § 1983—alleged a "failure to provide medical care needed" and claimed all the staff did "was to give (him) pain pills."[14] A United States magistrate judge recommended that the court grant permission to file the case, file the petition, deny Gamble request for appointment for counsel, and ultimately dismiss the claim for a failure to state a claim. The District Court judge agreed, and dismissed the case.[15] The court denied Gamble's motion to vacate this order and appoint counsel, and the Fifth Circuit granted his appeal.[16]

Circuit court[edit]

Opinion of the Court[edit]

Initial arguments[edit]

Majority opinion[edit]

Portrait of Justice Thurgood Marshall
Justice Thurgood Marshall, author of the majority opinion

Justice Thurgood Marshall delivered the opinion of the court.

Chief Justice Blackmun concurred with the Court's judgment although neither joined in the majority opinion nor wrote a separate concurring opinion.

Dissent[edit]

Portrait of Justice John Paul Stevens
Justice John Paul Stevens, author of the dissent


Subsequent developments[edit]

Helling v. McKinney[edit]

The Supreme Court in 1993 extended the requirement that inmates receive required medical care beyond what it established in Estelle. In Helling v. McKinney, the Court considered the case of a Nevada prisoner, "the cellmate of a five-pack-a-day smoker", who sought to be housed in an environment free of second-hand smoke. McKinney suffered from no ailment and sought no medical treatment. Justice Byron White wrote for a 7−2 majority of the Court that McKinney's claim that prison officials "have, with deliberate indifference, exposed him to levels of ETS [second hand smoke] that pose an unreasonable risk of serious damage to his future health" raised a valid claim under the Eighth Amendment. He wrote that McKinney would have to prove both the scientific facts of the dangers of exposure to second-hand smoke and prove that community standards supported him, that "it violates contemporary standards of decency to expose anyone unwillingly to such a risk. In other words, the prisoner must show that the risk of which he complains is not one that today's society chooses to tolerate." He would also have to prove that prison officials acted with "deliberate indifference."[17][18]

See also[edit]

Notes[edit]

  1. ^ Posner, Mark J. (1992). "The Estelle Medical Professional Judgment Standard: The Right of Those in State Custody to Receive High-Cost Medical Treatments". American Journal of Law & Medicine 18: 348–49. 
  2. ^ Id.
  3. ^ Trop v. Dulles, 356 U.S. 86, 100-01 (1958).
  4. ^ Gamble v. Estelle, 516 F.2d 937, 938 (5th Cir. 1975).
  5. ^ Id.
  6. ^ Id. at 938-39.
  7. ^ Gamble, 516 F.2d at 939.
  8. ^ Id.
  9. ^ Id.
  10. ^ Gamble, 516 F.2d at 939.
  11. ^ Id.
  12. ^ Estelle v. Gamble, 429 U.S. 97, 101 (1976)
  13. ^ Id.
  14. ^ Gamble, 516 F.2d at 938.
  15. ^ Id.
  16. ^ Id.
  17. ^ Helling v. McKinney, 509 U.S. 25 (1993)
  18. ^ Kosiak, Faryl (2013). Legal Aspects of Corrections Management, 3rd edition. Burlington, MA: Jones & Bartlett Learning. pp. 297–9. 

External links[edit]