 Due to the difficulty inherent in proving that a prison official knew about a medical condition, yet failed to respond to it, this standard makes it difficult to hold correctional facilities accountable for their mistakes.Todaro v. Ward argued that women within a New York prison did not have adequate, constitutional access to healthcare.Since Todaro v. Ward was the first major court case that called into question incarcerated women's actual access to health care, it spurred organizations such as the American Medical Association, American Correctional Association, and the American Public Health Association to start creating standards for health care within prisons.