The Tribunale di Catanzaro ruled that the liability for healthcare services provided to incarcerated individuals rests entirely with the National Health Service, or Servizio Sanitario Nazionale, while the Ministry of Justice retains exclusive jurisdiction over custody, facility security, and prison administration. According to court documents from the Italian tribunal, the ruling dismissed a damage claim filed by a prisoner because the plaintiff failed to establish a causal link between detention conditions and his declining health.
Jurisdiction Split Between Health Authorities and Prison Administration
According to the Tribunale di Catanzaro, legislative reforms initiated in 1999 and finalized in 2008 transferred the economic resources, medical equipment, and personnel of prison healthcare from the penitentiary administration to the National Health Service. This transition established a clear division of duties within Italian correctional facilities. Local health authorities, known as ASLs, manage and control medical services delivered to inmates, while the Ministry of Justice maintains responsibility for institutional safety, inmate supervision, and facility organization.
The case reviewed by the court involved an inmate with a history of severe cardiovascular conditions, including an aortic valve replacement and subsequent prosthetic implantations. In 2013, while detained in a prison facility in Calabria, the inmate experienced a rapid decline in cardiac and respiratory function. After multiple internal evaluations, his condition deteriorated further by January 2014, prompting a transfer to the hospital in Cosenza, where physicians diagnosed first- and second-degree atrioventricular block. Despite subsequent pacemaker implantation, the patient developed bacterial infective endocarditis in December 2014.
Court Findings on Medical Liability and Causation
The inmate filed a lawsuit against the Ministry of Justice at the Tribunale di Catanzaro, alleging that poor sanitary conditions inside the prison and delayed medical interventions caused his endocarditis and overall health deterioration. The Ministry of Justice entered an appearance in the proceedings and raised a preliminary exception regarding its lack of passive legitimacy, arguing that the responsibility for inmate medical care belonged entirely to the health service.
According to the judgment issued by the court, the Ministry of Justice indeed lacked passive legitimacy concerning the clinical treatment provided by the medical staff, because healthcare responsibilities had already shifted to the National Health Service by the time the inmate contracted endocarditis in December 2014. Consequently, any legal claim regarding alleged medical malpractice or treatment delays falls under the jurisdiction of the territorially competent ASL rather than the penitentiary administration.
Expert Medical Testimony and Case Dismissal
Despite establishing that the Ministry of Justice remains accountable for matters of custody, hygiene, and facility safety, the court evaluated whether institutional conditions contributed to the plaintiff’s illness. The experts concluded that specialists performed necessary diagnostic examinations promptly and accurately.
Furthermore, the expert medical board established that the bacterial endocarditis resulted from natural degenerative processes of the patient’s heart valves rather than from the sanitary conditions of the correctional institution. Because the plaintiff failed to prove a causal link between the prison’s hygiene standards or medical conduct and his cardiac complications, the Tribunale di Catanzaro dismissed the damage claim and ordered the inmate to pay approximately 15,000 euros in litigation costs alongside the expenses of the court-appointed medical experts.
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