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Estelle v. Gamble

Facts of the Case

Provided by Oyez

J. W. Gamble was a prisoner in the Huntington Unit of the Texas prison system, also known as the “Walls Unit.” On November 9, 1973, a 600-pound bale of cotton fell on Gamble while he was working in a textile mill during a work assignment in Huntsville, Texas. He continued to work for several hours, but later became stiff and requested a pass to the unit hospital. The hospital gave Gamble a checkup for a hernia and sent him back to his cell, but later his pain became so intense that he was forced to return to the hospital. A nurse gave Gamble two pain pills, and a hospital doctor later examined him but gave him no further treatment. On November 10th, a different doctor examined Gamble, prescribed him painkillers and placed Gamble on a cell-pass cell-feed routine that mostly confined him to his cell.

That same doctor later took Gamble off the cell-pass cell-feed routine, concluding that he was able to engage in light work. The prison administrative office soon placed Gamble in “administrative segregation” -- essentially solitary confinement -- for refusing to work. Gamble remained in solitary confinement through January of the next year, although he complained that his back pain was as intense as on the first day he was injured. On December 6, a different doctor examined Gamble and diagnosed him with high blood pressure; the previous doctor never detected this condition. Gamble refused to work several more times over the next few months, and was repeatedly disciplined for doing so. When Gamble began experiencing pain in his chest on a regular basis, he was hospitalized and treated, but the prison denied him later requests for treatment. In all, medical personnel treated Gamble seventeen times.

On February 11, 1974, Gamble signed a pro se complaint alleging that the prison subjected him to cruel and unusual punishment in violation of the Eighth Amendment, made applicable to the states by the Fourteenth. The district court dismissed Gamble’s complaint for failure to state a claim. The United States Court of Appeals, Fifth Circuit, reversed, noting that the prison failed to diagnose Gamble’s back injury by giving him an X-ray, that the prison provided no real treatment for Gamble’s back injury, and that Gamble was essentially placed in solitary confinement due to substandard medical care.

Questions

  1. Did Gamble’s pro se complaint that the Walls unit subjected him to cruel and unusual punishment raise a constitutional question or state a claim upon which relief can be granted?

  2. Did the Fifth Circuit err in reversing the district court’s summary dismissal of Gamble’s complaint because the complaint rested on a disagreement between licensed physicians about Gamble’s injury?

Conclusions

  1. No and yes. In an 8-1 decision written by Justice Thurgood Marshall, the Court held that the prison’s treatment of Gamble did not constitute cruel and unusual punishment under the Eighth Amendment. Justice Marshall acknowledged that the Eighth and Fourteenth Amendments required the Texas government to provide medical care for prisoners; he also determined, however, that a negligent or inadvertent failure to provide adequate medical care did not constitute medical mistreatment under the Constitution.

    Justice Marshall then considered whether Gamble’s complaint stated a claim, construing the pleadings of his inartfully written pro se complaint liberally. He focused on the fact that medical personnel treated Gamble on seventeen occasions in a three-month period. Justice Marshall argued that the form of medical treatment was a classic example of a matter for medical judgment; as a consequence, the doctor’s decision not to order an X-ray or provide additional medication did not constitute cruel or unusual punishment. Thus, the Fifth Circuit erred in reversing the district court’s dismissal of Gamble’s claim.

    Justice Harry Blackmun concurred in the Court’s judgment.

    Justice John Paul Stevens dissented. He argued that Court should have asked whether it could say with assurance and beyond any doubt that no set of facts could be proved that would entitle Gamble to relief. He questioned the Court’s decision to grant certiorari, noting that any constitutional questions presented by Gamble’s case were already resolved by other circuit courts. Finally, Justice Stevens argued that the majority improperly considered the defendants’ subjective motivations in determining whether or not their actions were crude or unusual.