Helling v. McKinney - 509 U.S. 25, 113 S. Ct. 2475 (1993)

Rule:

Although accidental or inadvertent failure to provide adequate medical care to a prisoner does not violate the Eighth Amendment, deliberate indifference to serious medical needs of prisoners violates the Amendment because it constitutes the unnecessary and wanton infliction of pain contrary to contemporary standards of decency. A claim that the conditions of a prisoner's confinement violate the Eighth Amendment requires an inquiry into the prison officials' state of mind. Whether one characterizes the treatment received by the prisoner as inhuman conditions of confinement, failure to attend to his medical needs, or a combination of both, it is appropriate to apply the deliberate indifference standard.

Facts:

Respondent McKinney, a Nevada state prisoner, filed suit against petitioner prison officials, claiming that his involuntary exposure to environmental tobacco smoke (ETS) from his cellmate's and other inmates' cigarettes posed an unreasonable risk to his health, thus subjecting him to cruel and unusual punishment in violation of the Eighth Amendment. A federal magistrate granted petitioners' motion for a directed verdict, but the Court of Appeals reversed in part, holding that McKinney should have been permitted to prove that his ETS exposure was sufficient to constitute an unreasonable danger to his future health. It reaffirmed its decision after this Court remanded for further consideration in light of Wilson v. Seiter, in which the Court held that Eighth Amendment claims arising from confinement conditions not formally imposed as a sentence for a crime require proof of a subjective component, and that where the claim alleges inhumane confinement conditions or failure to attend to a prisoner's medical needs, the standard for that state of mind is the "deliberate indifference" standard of Estelle v. Gamble, 429 U.S. 97, 50 L. Ed. 2d 251, 97 S. Ct. 285. The Court of Appeals held that Seiter's subjective component did not vitiate that court's determination that it would be cruel and unusual punishment to house a prisoner in an environment exposing him to ETS levels that pose an unreasonable risk of harming his health -- the objective component of McKinney's claim.

Issue:

Did the health risk allegedly posed by prison personnel's exposure of inmate to environmental tobacco smoke form proper basis of claim for relief under Federal Constitution's Eighth Amendment?

Answer:

Yes

Conclusion:

The United States Supreme Court held that the allegation that the prison officials had, with deliberate indifference, exposed inmates to levels of ETS that posed an unreasonable risk of serious damage to the inmate's future health was a valid claim under the Eighth Amendment. The Court also held that the inmate would be required to prove both the subjective and objective elements necessary to prove an Eighth Amendment violation. The subjective factor, deliberate indifference, had to be determined in light of the prison officials' current attitudes and conduct demonstrating that the prison officials were ignoring the possible dangers to inmates exposed to ETS.