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McKinney that, "McKinney states a cause of action under the Eighth Amendment [cruel and unusual punishment clause] by alleging that petitioners have, with deliberate indifference, exposed him to levels of ETS [environmental tobacco smoke] that pose an unreasonable risk of serious damage to his future health." (4) Will continuing inmate success in secondhand smoke lawsuits eventually compel all prisons to both adopt and enforce smoke-free policies

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