Case law · Highest court · Federal

Estelle v. Gamble

Decided
November 30, 1976
Docket
75-929
Status
Published
Jurisdiction
Federal

Cited 28,035 timesNo negative treatment found in this library

What later courts said

  • holding that a defendant’s action or inaction could be “sufficiently harmful to evidence deliberate indifference to serious medical needs” — John C. McGuckin v. Dr. Smith John C. Medlen, Dr. (1992)
  • holding that deliberate indifference to a prisoner’s serious medical needs constitutes an Eighth Amendment violation — Palmer v. Johnson (1999)
  • holding that "an inadvertent failure to provide adequate medical care" is not a constitutional violation — Kosilek v. Spencer (2014)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

Mr. Justice Marshall delivered the opinion of the Court.

Respondent J. W. Gamble, an inmate of the Texas Department of Corrections, was injured on November 9, 1973, while performing a prison work assignment. On February 11, 1974, he instituted this civil rights action under 42 U. S. C. § 1983,[1] complaining of the treatment he received after the injury. Named as defendants were the petitioners, W. J. Estelle, Jr., Director of the Department of Corrections, H. H. Husbands, warden of the prison, and Dr. Ralph Gray, medical director of the Department and chief medical officer of the prison hospital. The District Court, sua sponte, dismissed the complaint for failure to state a claim upon which relief could be granted.[2] The Court of Appeals reversed and remanded with instructions to reinstate the complaint. 516 F. 2d 937 (CA5 1975). We granted certiorari, 424 U. S. 907 (1976).

[*99] I Because the complaint was dismissed for failure to state a claim, we must take as true its handwritten, pro se allegations. Cooper v. Pate, 378 U. S. 546 (1964). According to the complaint, Gamble was injured on November 9, 1973, when a bale of cotton[3] fell on him while he was unloading a truck. He continued to work but after four hours he became stiff and was granted a pass to the unit hospital. At the hospital a medical assistant, “Captain” Blunt, checked him for a hernia and sent him back to his cell. Within two hours the pain became so intense that Gamble returned to the hospital where he was given pain pills by an inmate nurse and then was examined by a doctor. The following day, Gamble saw a Dr. Astone who diagnosed the injury as a lower back strain, prescribed Zactirin (a pain reliever) and Robaxin (a muscle relaxant),[4] and placed respondent on “cell-pass, cell-feed” status for two days, allowing him to remain in his cell at all times except for showers. On November 12, Gamble again saw Dr. Astone who continued the medication and cell-pass, cell-feed for another seven days. He also ordered that respondent be moved from an upper to a lower bunk for one week, but the prison authorities did not comply with that directive. The following week, Gamble returned to Dr. Astone. The doctor continued the muscle relaxant but prescribed a new pain reliever, Febridyne, and placed respondent on cell-pass for seven days, permitting him to remain in his cell except for meals and showers. On November 26, respondent again saw Dr. Astone, who put respondent back on the original pain reliever for five days and continued the cell-pass for another week.

Statutes cited

Cite this

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

Read the full opinion

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