As an inmate of a state or Federal prison, an individual is entitled to medical care through the prison system. When there is a denial of Medical Care to inmates, an inmate’s constitutional rights may have been violated. Under the 8th Amendment to the United States Constitution, a person cannot be subjected to cruel and unusual punishment. From this doctrine, denial of medical care to an inmate may be seen as inflicting cruel and unusual punishment on the inmate in violation of their constitutional right.
In the seminal case of Estelle v. Gamble (429 U.S. 97), the United States Supreme Court determined that in order for a denial of medical care to be classified as cruel and unusual punishment, there must exist a deliberate indifference to the serious medical needs of the inmate by an official or the administration of the prison. This standard requires more then just showing simple negligence, it requires that the inmate show that a prison official recklessly disregarded the inmate’s medical needs. In other words, the official must have actively known and ignored an inmate’s medical issues. Denial of medical care to inmates is determined by whether there is proof of deliberate indifference to the inmate’s constitutional rights.
Establishing deliberate indifference by a prison official is a tricky task. Since many of the examples of deliberate indifference turn on the prison official’s state of mind or intent, proving deliberate indifference is not easy. However, if from the surrounding circumstances it is blatantly obvious that the officials were deliberately indifferent, overcoming the intent element is far easier. Examples of deliberate indifference are: ignoring obvious medical issues, delaying or refusing treatment, or withholding medical treatment due to some non-medical reason. Denial of medical care to inmates only triggers a constitutional violation when there is evidence of deliberate indifference.
Although there is no law that states that prison facilities must provide comfort to an inmate, the law does state that the healthcare an inmate receives must be up to a reasonable standard of treatment and care and should employ adequate medicine and technology. This requirement puts the burden of providing and supplying adequate healthcare on prison officials in order to be in compliance with the law. Denial of medical care to inmates who are in need of treatment could give rise to further investigation of a prison’s treatment of all of its inmates.
This rule however does not give inmates, whether of jails or prisons, the supreme ability to take officials to court for any perceived slight to their medical care. The courts have interpreted that deliberate indifference to serious medical needs does not exist in a variety of situations such as: accidental negligence, malpractice, or a difference of opinion between the inmate and doctor in treatment plans. When evaluating whether a medical official made the appropriate decision regarding treatment of an inmate, the courts will also generally defer to the medical official’s opinion on the appropriate treatment.
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James Minick is a criminal defense attorney in Asheville, NC and is the owner of Minick Law, P.C.