In the 1976 case Estelle, Corrections Director, et al. v. Gamble, J.W. Gamble filed a lawsuit against the Texas Department of Corrections claiming that his Eighth Amendment rights were violated due to inadequate medical treatment while he was in prison for a felony conviction. The Supreme Court ruled in favor of the corrections department with a 5-4 decision stating that deliberate indifference to serious medical needs constitutes unnecessary and wanton infliction of pain which is prohibited by the Eighth Amendment; however, an accidental failure to provide adequate medical care or negligence in diagnosing or treating a condition does not constitute 'cruel and unusual punishment'. In this particular case, it was found that there wasn't enough evidence proving officials showed "deliberate indifference" towards Gamble's health issues - hence no constitutional violation occurred.

In the dissenting opinion for Estelle, Corrections Director, et al. v. Gamble (1976), Justice William Rehnquist argued that the majority's decision expanded the Eighth Amendment's prohibition of "cruel and unusual punishments" beyond its intended scope. He contended that this amendment was originally designed to prevent torturous methods of punishment rather than regulate every aspect of medical care in prisons. Furthermore, he expressed concern over federal courts becoming involved in daily prison operations due to complaints about inadequate medical treatment from inmates - a situation he believed would lead to an unmanageable influx of cases and distract from more serious constitutional violations within correctional facilities.