Reference Number: 
CTAS-1382

The requirement that the state furnish healthcare includes necessary dental services. Grubbs v. Bradley, 552 F.Supp. 1052, 1123 (D.C. Tenn. 1982). Pursuant to state regulations, dental treatments, not limited to extractions, must be provided when the health of the inmate would otherwise be adversely affected during confinement, as determined by a physician or dentist. Rules of the Tennessee Corrections Institute, Rule 1400-1-.13(15).

“[N]ot all claims regarding improper dental care will be constitutionally cognizable. Dental conditions, like other medical conditions, may be of varying severity. The standard for Eighth Amendment violations contemplates ‘a condition of urgency’ that may result in ‘degeneration’ or ‘extreme pain.’” Chance v. Armstrong, 143 F.3d 698, 702 (2nd Cir. 1998). “A cognizable claim regarding inadequate dental care, like one involving medical care, can be based on various factors, such as the pain suffered by the plaintiff, the deterioration of the teeth due to a lack of treatment, and the inability to engage in normal activities." Goodnow v. Palm, 264 F.Supp.2d 125, 132 (D. Vt. 2003) (citations omitted).  See also Fields v. Gander, 734 F.2d 1313, 1314-1315 (8th Cir. 1984) (Inmate’s claims that sheriff knew of the pain he was suffering and still refused to provide dental care for him for up to three weeks could support a finding of an Eighth Amendment violation.).