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The Eighth Amendment may be applied to some deprivations that are not specifically part of a sentence but are suffered during imprisonment. The United States Supreme Court has rejected, however, prisoners' claims of cruel and unusual punishment due to inadequate attention to medical needs where the prisoners failed to establish that prison doctors possessed a sufficiently culpable state of mind. Because only the unnecessary and wanton infliction of pain implicates the Eighth Amendment, a prisoner advancing such a claim must, at a minimum, allege "deliberate indifference" to his "serious" medical needs. It is only such indifference that can violate the Eighth Amendment; allegations of inadvertent failure to provide adequate medical care or of a negligent diagnosis simply fail to establish the requisite culpable state of mind.
Petitioner Wilson, an Ohio prison inmate, brought an action under 42 USCS 1983 in the United States District Court for the Southern District of Ohio against the director of the state department of correction and the warden of the prison, alleging that certain conditions of his confinement constituted cruel and unusual punishment in violation of the Federal Constitution's Eighth and Fourteenth Amendments. The parties filed cross motions for summary judgment with supporting affidavits. The petitioner’s affidavits described the challenged conditions and alleged that the prison authorities had failed to take remedial action after being notified of those conditions. In their affidavits, the prison authorities denied that some of the challenged conditions existed and described efforts which had been made to improve the others. The District Court granted summary judgment to the prison authorities, and the United States Court of Appeals for the Sixth Circuit affirmed, stating that certain of the petitioner’s claims, even if proved, did not involve a sufficiently serious deprivation of human needs to constitute an Eighth Amendment violation. With respect to his remaining claims, the appellate court held that the petitioner was required to show that the prison officials had acted with "persistent malicious cruelty." The appellate court concluded that the petitioner’s claims, at best, evidenced only negligence on the part of the prison authorities. The United States Supreme Court granted a writ of certiorari.
Should a prisoner, who claimed that the conditions of his confinement constitute cruel and unusual punishment, show a culpable state of mind on the part of prison officials?
After granting certiorari, the Supreme Court stated that the lower courts were required to inquire into the prison officials' state of mind because the petitioner claimed that he was subjected to cruel and unusual punishment. In order for the petitioner to recover, the offending conduct had to have been wanton to constitute a violation of the Eighth Amendment. The lower courts improperly believed that the criterion for liability was whether the prison officials acted maliciously and sadistically for the purpose of causing harm. According to the Court, the applicable legal standard in this context was the "deliberate indifference" standard, previously applied by the Supreme Court to Eighth Amendment claims based on allegations of inadequate medical care of prisoners. The case was vacated and remanded for reconsideration under the appropriate standard.