## Facts

- J. W. Gamble, a Texas prison inmate, injured his back when a cotton bale fell on him during a work assignment.
- Over the next three months, he repeatedly complained of back and chest pain and was seen by medical staff numerous times, receiving examinations, medication, rest orders, and tests.
- Gamble alleged the treatment was inadequate, including failure to order X-rays or other diagnostics and requiring him to work despite pain.
- He sued prison officials and a prison doctor under 42 U.S.C. § 1983, claiming unconstitutional denial of medical care in violation of the Eighth Amendment.

## Issues

1. What standard governs when inadequate prison medical care constitutes cruel and unusual punishment under the Eighth Amendment.
2. Whether allegations amounting to negligent diagnosis or treatment (including decisions not to order specific tests) state an Eighth Amendment claim.
3. Whether Gamble’s complaint stated an Eighth Amendment claim against the prison doctor and against prison administrators.

## Decision

- The Supreme Court reversed the Fifth Circuit and remanded.
- The Court held that only “deliberate indifference to serious medical needs” constitutes cruel and unusual punishment in the prison medical-care context.
- The Court concluded the allegations against the prison doctor and medical staff showed repeated treatment and, at most, negligence or medical malpractice, which is not an Eighth Amendment violation.
- The Court remanded for separate consideration of whether the complaint stated a constitutional claim against the prison director and warden.

## Legal Principles

- Deliberate indifference to a prisoner’s serious medical needs constitutes the “unnecessary and wanton infliction of pain” prohibited by the Eighth Amendment.
- The deliberate-indifference standard can be satisfied by acts or omissions, including intentionally denying or delaying access to medical care or intentionally interfering with prescribed treatment.
- Medical malpractice, negligent diagnosis, or inadvertent failure to provide adequate medical care does not, without more, amount to cruel and unusual punishment.
- Disagreements over medical judgment, such as choosing not to order an X-ray or particular diagnostic measure, ordinarily do not present a constitutional violation.

## Conclusion

The Court established that prisoners may state an Eighth Amendment claim for denial of medical care only by alleging deliberate indifference to serious medical needs, drawing a clear line between constitutional wrongdoing and ordinary negligence or malpractice, and it required further consideration of the allegations against nonmedical prison administrators on remand.


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