McKinney was a nonsmoker who claimed that his exposure to ETS caused nosebleeds, headaches, chest pains, and lack of energy. The district court defined the issue in all or nothing terms, holding that either the prisoner had a right to an entirely smoke-free environment or that the right was only to medical attention for proven serious medical needs. The court of appeals ruled this dichotomy to be in error and accepted a middle position stating that involuntary exposure to levels of ETS that pose an unreasonable risk of harm to human health represents cruel and unusual punishment. The Supreme Court asked that the case receive further consideration in view of Wilson v. Seider, which held that prison officials' deliberate indifference to serious medical needs must be demonstrated. Although the McKinney decision is weakened by the Wilson decision, it will still help inmates improve the conditions of their confinement, particularly when the conditions create health hazards as great as those posed by constant exposure to ETS. Footnotes