How the Tenth Circuit’s Ruling in Martinez v. Beggs Affects the Deliberate Indifference Standard for Eighth Amendment Claims

I. INTRODUCTION In Martinez v. Beggs,1 the Tenth Circuit held that prison officials were not hable under Section 19832 for a detainee's death. Because the prison officials were not "deliberately indifferent to the specific risk" of the harm, which in this case was a heart attack that led to the detainee's death,3 the court reasoned that the prison officials were not Hable under Section 1983 for violating the detainee's Eighth Amendment rights.4 The Tenth Circuit's holding, however, that a prison official must be deliberately indifferent toward the specific risk faced by detainees changes the deliberate indifference standard for Eighth Amendment claims set by the Supreme Court in Farmer v. Brennan.5 In Farmer, the Court did not require knowledge of the specific risk, and instead, only required that the official must be "aware of facts from which the inference could be drawn that a substantial risk of serious harm exists."6 Additionally, the holding in Martinez disregards prior Tenth Circuit precedent, conflicts with other circuit court holdings, and unreasonably requires that all prison officials be sufficiently knowledgeable to understand a detainee's specific medical risks. Understanding how the Tenth Circuit's decision in Martinez disregards prior Tenth Circuit precedent and unreasonably changes the deliberate indifference standard requires reviewing the facts and reasoning in Martinez and the Supreme Court's precedent concerning pretrial detainee's Eighth Amendment rights. Specifically, Part II of this article discusses the relevant Supreme Court precedent, Part III provides the facts and holding in Martinez, and Part IV analyzes the court's holding. II. THE DELIBERATE INDIFFERENCE STANDARD IN ESTELLE V. GAMBLE AND FARMER V. BRENNAN Two Supreme Court cases set the standard for violating a pretrial detainee's Eighth Amendment rights. First, in Estelle v. Gamble, the Court held that deliberate indifference to a prisoner's serious medical needs constitutes the "unnecessary and wanton infliction of pain" proscribed by the Eighth Amendment.7 Second, in Farmer v. Brennan, the Court defined deliberate indifference as disregarding a substantial risk by a prison official if the official was "aware of the facts from which the inference could be drawn that a substantial risk of serious harm exists," and if the prison official actually made this inference.8 A. The Facts and Holding in Estelle v. Gamble J. W. Gamble, a Texas Department of Correction's inmate, was significantly injured when a 600-pound bale of cotton fell on him while performing a work assignment.9 Because of the accident, Gamble suffered intense pain and lower back strain.10 A doctor gave Gamble pain relievers, muscle relaxants, and a work pass that relieved the inmate of his work duties.11 Nearly three weeks later, the doctor took away Gamble's pass and cleared Gamble for fight work.12 However, Gamble refused to work, stating that he was still in too much pain.13 Because of his refusal to work, Gamble was moved to administrative segregation and was permitted to see another doctor.14 The new doctor prescribed more pain medication and some high blood pressure medication.15 After a few more weeks, and after Gamble still refused to work, the prison disciplinary committee placed Gamble in solitary confinement.16 While there, Gamble asked to see a doctor for chest pains and "blank outs."17 About twelve hours later, Gamble saw a medical assistant who ordered him hospitalized.18 At the hospital, on the following day, a doctor prescribed medication for irregular cardiac rhythm.19 Two days later, Gamble again asked to see a doctor for chest pains and pain in his left arm and back;20 however, the guards refused. On the next day, Gamble again asked to see a doctor, but again, the guards denied his request.21 Finally, on the third day of asking to see a doctor, the guards allowed Gamble to see a doctor. …