In Estelle v. Gamble, the Court determined that the government's failure to provide adequate medical care for those whom it punishes by incarceration would result in unnecessary pain and suffering, a violation of the eighth amendment's prohibition against cruel and unusual punishment. Subsequent related court cases have established that prison systems must minimally offer an adequate screening and classification system designed to determine inmate medical needs and maintain accurate medical records to promote continuity of treatment. Adequate psychological treatment is largely determined by the number and type of staff and apparently requires at least sufficient procedures to address emergency needs and provide access to a psychiatrist. Beyond this, courts vary widely as to what else, if anything, is required to achieve constitutional minima for mental health services. Generally, when special psychological needs can be proven, such as the unique needs of death row inmates or an identifiable and severe drug or alcohol problem, the courts have required special response to those needs, such that unnecessary suffering is eliminated. 235 footnotes.