Estelle v. Gamble - 429 U.S. 97, 97 S. Ct. 285 (1976)

Rule:

Deliberate indifference to serious medical needs of prisoners constitutes the unnecessary and wanton infliction of pain proscribed by U.S. Const. amend. VIII. This is true whether the indifference is manifested by prison doctors in their response to the prisoner's needs or by prison guards in intentionally denying or delaying access to medical care or intentionally interfering with the treatment once prescribed. Regardless of how evidenced, deliberate indifference to a prisoner's serious illness or injury states a cause of action under 42 U.S.C.S. § 1983.

Facts:

Respondent J. W. Gamble, an inmate of the Texas Department of Corrections, was injured on Nov. 9, 1973, while performing a prison work assignment. On Feb. 11, 1974, he instituted a civil rights action in federal district court under 42 U.S.C.S. § 1983, against the petitioners, W. J. Estelle, Jr., Director of the Department of Corrections, H. H. Husbands, warden of the prison, and Dr. Ralph Gray, medical director of the Department and chief medical officer of the prison hospital. Gamble asserted that he was subjected to cruel and unusual punishment in violation of the Eighth Amendment for inadequate treatment of the injury he sustained during the prison work. The district court, sua sponte, dismissed the complaint for failure to state a claim upon which relief could be granted. The court of appeals reversed and remanded with instructions to reinstate the complaint. The Supreme Court of the United States granted certiorari.

Issue:

Did Gamble's complaint sufficiently state a claim upon which relief could be granted?

Answer:

No.

Conclusion:

According to the Supreme Court of the United States, the general rule was that deliberate indifference to a prisoner's serious medical needs constituted cruel and unusual punishment under the Eighth Amendment and gave rise to a civil rights cause of action under 42 U.S.C.S. § 1983, regardless of whether the indifference was manifested by prison doctors in their response to the prisoner's needs or by prison guards in intentionally denying or delaying access to medical care or intentionally interfering with treatment once prescribed. However, in the case at bar, Gamble's complaint against petitioners did not suggest such indifference, the allegations revealing that Gray and other medical personnel saw respondent on 17 occasions during a 3-month span and treated his injury and other problems.