It is "'just that the public be required to care for the prisoner, who cannot by reason of the deprivation of his liberty, care for himself.'"

In light of this, the Court held that the State has a constitutional obligation, under the Eighth Amendment, to provide adequate medical care to those whom it has incarcerated.

Implementing section 16-3-401 served that broad purpose by codifying the common law rule that prisoners must be cared for by the public who sanctions their detention.

While incarcerated, a prisoner is forced to rely on prison officials for her medical needs, and failure to provide for those needs can, in extreme cases, amount to torture and death.

—liability on the part of county commissioners to provide necessary medical care to prisoners confined in jail was based on a statutory duty.