Estelle v Gamble
Question(s)
- Is the grievance of Gamble, an inmate who was injured on the job while performing prison corrections work, necessary to address the constitutional protections guaranteed by the Eighth Amendment, and should legal protection be afforded to the disabled inmate?
- Is there an error in the district court’s order dismissing the lawsuit on Gamble’s behalf?
Rule(s)
- Gamble’s pro se complaint.
- 42 USC § 1983.
- The Eighth Amendment of the U.S. Constitution.
- The Fourteenth Amendment.
Analysis
On February 11, 1974, an inmate who had previously been injured on the job while performing prison work wrote a complaint to the district court alleging that the prison medical authority had failed to provide any meaningful quality medical care that should have been provided in compliance with 42 USC § 1983. In addition, the plaintiff argued, his constitutional rights guaranteed by the Eighth Amendment were violated. As a matter of jurisprudence, the district court dismissed the suit for the insufficient cause of action. The case was remanded to the Court of Appeals, which considered the legality of the refusal to form the suit using the Eighth and Fourteenth Amendment texts as the statutory basis.
Conclusion
Both yes and no at the same time. The court found that although the medical authority did not demonstrate harsh or improper treatment of the injured prisoner, the lack of medical support was established: the complaint was granted.
Thoughts
Any constitutional amendment cases seem to me to be the most important and meaningful because they shape decisions to unanswered questions. In this case, I am drawn to the plaintiff’s tenacity, and the result: many correctional facilities have changed their medical service structure to achieve better results.
Lynce v. Mathis
Question(s)
Is the 1992 administrative regulation created to revoke temporary parole credits for prisoners retroactively in violation of Ex Post Facto clauses?
Rule(s)
- Florida’s 1992 law abolishing temporary release credits.
- Prison Overcrowding Points Act.
- Ex Post Facto Law.
- 11th Circuit 2 and Florida 3.
- Arnold v. Cody, 951 F. 2d 280 (1991).
- Weaver v. Graham, 450 U.S. 24.
Analysis
Plaintiff sent a complaint to the court that Florida’s 1992 law, which eliminated temporary release credits for prisoners due to prison overcrowding, violated Ex Post Facto Law. In response, several district courts gave different opinions: some guided by similar cases (11th Circuit 2 and Florida 3) and refused to form a claim, while others used an opinion from alternative court cases (Arnold v. Cody) to prove the validity of the claim and the illegality of the repeal of the credit. Using the record in Weaver v. Graham, the court held that the lifting of the injunctions was a retrospective action reducing the offender’s benefit, which subsumed a violation of o Ex Post Facto Law.
Conclusion
Yes, an absolute majority of the justices found that such a retrospective order was in direct violation of the Ex Post Facto clauses, and therefore it was unlawful to detain a released prisoner again.
Thoughts
There are mixed feelings about this case because, on the one hand, the idea of early release of prisoners on temporary credit seems ill-advised. While I recognize the importance of such a progressive incarceration model, I cannot be sure of its transparency. On the other hand, administrative rulings like the 1992 law seem downright cruel since they override any regulations retroactively. I am sure that such ordinances are only intended to benefit a narrow circle of individuals.