Gregory Atkins, et al. v. Kenneth Williams, Medical Director, Tennessee Department of Correction

The Eighth Amendment prohibits cruel and unusual punishments, including deliberate indifference to a convicted prisoner’s serious medical needs and other basic requirements. This prohibition applies to States through the Fourteenth Amendment, and inmates have a right of action to enforce it under 42 U.S.C. § 1983. The deliberate indifference standard requires proof of an objectively serious need on the part of the inmate, as well as a culpable mental state on the part of the defendant. The federal courts of appeals have split on whether a lack of funds or other resources can defeat a deliberate indifference claim by undercutting the mental state requirement. In the typical scenario, a State has underfunded its prison system, preventing officials from delivering medical treatment, security, or proper sanitation. A number of circuits only recognize the lack of funds defense when an inmate is trying to hold a prison official personally liable for damages, not in cases for injunctive relief to improve prison conditions going forward. A few circuits do not recognize the lack of funds defense at all, regardless of the relief sought. Going to the other extreme, the Sixth Circuit held in this case that inmates cannot even get an injunction if the defendant shows that poor prison conditions resulted from a lack of funds. The questions presented are: 1. Does the unavailability of funds or other resources negate the subjective component of a deliberate indifference claim under the Eighth Amendment?