What is the standard for denial of medical care of a convicted convicted mentally disabled person?

In Youngberg v. Romeo (1982) 457 U.S. 307, 102 S.Ct. 2452, 73 L.Ed.2d 28, which involved the due process rights of an involuntarily committed mentally retarded person, the court first noted that the standard articulated in Estelle v. Gamble [ (1976) 426 U.S. 97, 97 S.Ct. 285, 50 L.Ed.2d 251] for denial of medical care of convicted persons had been erroneously applied by the lower court. (Youngberg v. Romeo, supra, 457 U.S. 307, 312, fn. 11, 102 S.Ct. 2452, 2456, fn. 11.) The court concluded that the involuntarily committed person had a right to adequate food, shelter, clothing, and medical care and also to safe conditions, freedom from bodily restraint and minimally adequate care or reasonable training to ensure safety and freedom from undue restraint. Liability would be imposed "when the decision by the professional [regarding care of the committed person] is such a substantial departure from accepted professional judgment, practice, or standards as to demonstrate that the person responsible actually did not base the decision on such a judgment." (Youngberg v. Romeo, supra, at p. 323, 102 S.Ct. at 2462, fn. omitted.) Under either standard, the facts as alleged would constitute a cause of action under section 1983.