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Estelle v. Gamble Case of 1976

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

The Supreme Court's Estelle v. Gamble case of 1976 marked the first time the court considered the kind of proof necessary to prove the violation of a prisoner's Eighth Amendment rights. This lesson discusses the facts of the case as well as the Supreme Court's holding and analysis.

The Facts of Estelle v. Gamble

The story behind the Supreme Court's landmark Estelle v. Gamble case of 1976 begins on a Texas prison farm in 1973. Inmate G.W. Gamble was unloading cotton bales from a truck in accordance with his prison labor assignment. Suddenly, a cotton bale fell onto Gamble, causing him to injure his back.

Gamble worked until the pain became too severe to continue. A medical assistant in the prison hospital examined Gamble and sent him back to his cell. But soon enough, the pain intensified and Gamble found himself back in the prison hospital. Eventually, a doctor examined Gamble and prescribed him medication for the pain.

Over the course of several months, Gamble was in and out of the prison hospital complaining of severe back pain and migraines. During that time, Gamble was repeatedly disciplined by prison officers for refusing to work on the prison farm. When Gamble complained of worsening chest pains, prison guards refused to allow him to see a doctor for three days.

Gamble drafted a 'pro se' complaint (i.e., without legal representation) alleging that the prison violated of his Eighth Amendment rights. It was Gamble's argument that the prison's failure to adequately treat his injured back constituted cruel and unusual punishment. Gamble's case made it all the way to the Supreme Court of the United States.

The Question Presented to the Supreme Court

The Eighth Amendment to the United States Constitution prohibits the government from inflicting 'cruel and unusual' punishment on convicted criminals. But when does the treatment of a prisoner rise to the level of unconstitutional cruel and unusual punishment?

The Holding and Analysis of the Supreme Court

The Supreme Court held that cruel and unusual punishment includes the 'deliberate indifference to serious medical needs of prisoners'. Therefore, any action or omission of a prison that results in the 'unnecessary and wanton infliction of pain' on an inmate constitutes an violation of the prisoner's Eighth Amendment right to be free from cruel and unusual punishment.

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