Helling v. McKinney
Supreme Court of the United States
January 13, 1993, Argued ; June 18, 1993, Decided
[*27] [***28] [**2478] JUSTICE WHITE delivered the opinion of the Court.
This case [****5] requires us to decide whether the health risk posed by involuntary exposure of a prison inmate to environmental [*28] tobacco smoke (ETS) can form the basis of a claim for relief under the Eighth Amendment.
Respondent is serving a sentence of imprisonment in the Nevada prison system. At the time that this case arose, respondent was an inmate in the Nevada State Prison in Carson City, Nevada. Respondent filed a pro se civil rights complaint in United States District Court under Rev. Stat. § 1979, 42 U.S.C. § 1983, naming as defendants the director of the prison, the warden, the associate warden, a unit counselor, and the manager of the prison store. The complaint, dated December 18, 1986, alleged that respondent was assigned to a cell with another inmate who smoked five packs of cigarettes a day. App. 6. The complaint also stated that cigarettes were sold to inmates without properly informing of the health hazards a nonsmoking inmate would encounter by sharing a room with an inmate who smoked, Id., at 7-8, and that certain cigarettes burned continuously, releasing some type of chemical, Id., at 9. Respondent complained of certain health [****6] problems allegedly caused by exposure to cigarette smoke. Respondent sought injunctive relief and damages for, inter alia, subjecting him to cruel and unusual punishment by jeopardizing his health. Id., at 14.
The parties consented to a jury trial before a magistrate. The magistrate viewed respondent's suit as presenting two issues of law: (1) whether respondent had a constitutional right to be housed in a smoke-free environment, and (2) whether defendants were deliberately indifferent to respondent's serious medical needs. App. to Pet. for Cert. D2-D3. The magistrate, after citing applicable authority, concluded that respondent had no constitutional right to be free from cigarette smoke: while "society may be moving toward an opinion as to the propriety of non-smoking and a smoke-free environment," [***29] society cannot yet completely agree "on the resolution of these issues." Id., at D3, D6. The magistrate [*29] found that respondent nonetheless could state a claim for deliberate indifference to serious medical needs if he could prove the underlying facts, but held that respondent had failed to present evidence showing either medical problems that were traceable to cigarette smoke [****7] or deliberate indifference to them. Id., at D6-D10. The magistrate therefore granted petitioners' motion for a directed verdict and granted judgment for the defendants. Id., at D10.
The Court of Appeals affirmed the magistrate's grant of a directed verdict on the issue of deliberate indifference to respondent's immediate medical symptoms, McKinney v. Anderson, 924 F.2d 1500, 1512 (CA9 1991). The Court of Appeals also held that the defendants were immune from liability for damages since there was at the time no clearly established law imposing liability for exposing prisoners to ETS. Although it agreed that respondent did not have a constitutional right to a smoke-free prison environment, the court held that respondent had stated a valid cause of action under the Eighth Amendment by alleging that he had been involuntarily exposed to levels of ETS that posed an unreasonable risk of harm to his future health. Id., at 1509. In support of this judgment, the court noticed scientific opinion supporting respondent's claim that sufficient exposure to ETS could endanger one's health. Id., at 1505-1507. [****8] The court also concluded that society's attitude had evolved to the point that involuntary exposure to unreasonably dangerous levels of ETS violated current standards of decency. Id., at 1508. The court therefore held that the magistrate erred by directing a verdict [**2479] without permitting respondent to prove that his exposure to ETS was sufficient to constitute an unreasonable danger to his future health.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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509 U.S. 25 *; 113 S. Ct. 2475 **; 125 L. Ed. 2d 22 ***; 1993 U.S. LEXIS 4210 ****; 61 U.S.L.W. 4648; 93 Cal. Daily Op. Service 4501; 93 Daily Journal DAR 7681; 7 Fla. L. Weekly Fed. S 452
DONALD L. HELLING, ET AL., PETITIONERS v. WILLIAM McKINNEY
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
Disposition: 959 F.2d 853, affirmed and remanded.
exposure, inmate, prison, exposed, deliberate indifference, inflicted, sentence, smoke, conditions of confinement, prison conditions, deprivations, cigarette, effects, slip opinion, decency, cruel and unusual punishment, serious medical needs, decisions, injuries, Rights, levels, cases, cruel
Civil Rights Law, Protection of Rights, Prisoner Rights, Confinement Conditions, Criminal Law & Procedure, Sentencing, Cruel & Unusual Punishment, Healthcare Law, Healthcare Litigation, Actions Against Healthcare Workers, Prison Officials & Physicians, Medical Treatment, Constitutional Law, Bill of Rights, Fundamental Rights, Postconviction Proceedings, Imprisonment, Medical Treatment, Failures & Refusals to Treat, Prisoners, Safety