Sloat v. Benzing & the other Miranda Case on Medical Issues in Jail & Prison
Are inmates entitled to decent medical care? The Sloat medical treatment case and the "not the famous" Miranda case unequivocally say "yes". Prison and Jail doctors can be sued for constitutional violations and the doctors in Sloat and Miranda would likely face potential medical malpractice and medical board actions as well. [Cite to Sloat v. Benzing 2020 WL 5981422] Here is the law.
Sloat addresses whether medical treatment in a jail meets Eighth Amendment standards. The Miranda case (Miranda v. City of Lake) addresses the same issue in a Fourteenth Amendment context. Sloat is not a medical malpractice case but it sounds like one. Sloat alleged that a nurse, Jail Administrator and others denied him access to prescription medicines leading to seizures.
The Miranda case like Sloat, was not a medical malpractice case but involved the issue of access to medical care. In Miranda (like Sloat) the person suing stated that the jail had a policy of depriving detainees of an intake evaluation by a medical professional and this lack of an evaluation meant that pretrial detainees were prevented from getting prescribed medication for serious medical conditions., 2020 WL 5981422, at *2 (S.D. Ill. Oct. 8, 2020)
In the case of Walker v. Sloat the court noted that “ Although “the Constitution does not mandate comfortable prisons,” Rhoades v. Chapman, 452 U.S. 337, 349 (1981), inmates are entitled to adequate food, clothing, shelter, bedding, hygiene materials, sanitation, and medical care.” [Cite to Walker v. Sloat is 2022 WL 16552959]
The bottom line is that being arrested or convicted does not allow the withholding of medical care as a punishment. “[P]rison officials violate the Eighth Amendment [cruel & unusual punishment] when they act deliberately indifferent to a prisoner's serious medical needs by ‘intentionally denying or delaying access to medical care or interfering with the treatment once prescribed.’ ” Pearson v. Prison Health Serv., 850 F.3d 526, 534 (3d Cir. 2017) (quoting Estelle v. Gamble, 429 U.S. 97, 104-05 (1976)).
Ultimately the level of care for in custody patients need not be top of the line or preventative. However, missing a clear symptom that would require additional testing and diagnosis; failing to evaluate the ongoing needs of a patient including his history are within the standard of medical care and constitutionally required.
In California the California Department of Corrections and Rehabilitation (CDCR), in partnership with the federal Plata Receiver, is responsible for health care services to all inmate patients. Mental Health and Dental services are provided by the CDCR’s Division of Health Care Services (DHCS). A federal Plata Receiver is someone appointed by the court to control of some aspect of prison or jail operations. The Receiver appointed by the Plata court has a mandate to bring the department's provision of medical care into compliance with federal constitutional standards. In other words, the standards in the cases cited above were not met in California.
The prison health care issue is highly contentious and prisoners are often denied proper medical care but other times doctors or nurses are blamed and sued for problems outside of their control. The prison administration will make the medical staff the punching bag for problems that were created by the institution. The Sloat cases and Miranda are factually very typical and easy to understand in terms of the factual history. In most instances tying down the facts is difficult as records are sparsely kept and often altered and destroyed.
Daniel Horowitz is a criminal defense attorney with a nationwide practice. He also represents medical doctors in licensing and board actions. He is uniquely qualified to evaluate a medical quality of care case apply Sloat, Miranda and myriad of other cases addressing medical care issues. Contact Daniel if you are on either side of a medical care in custody issue.