In 2005, Henderson found that substandard medical care in the California prison system had violated prisoners' rights under the Eighth Amendment to the United States Constitution to be protected from cruel and unusual punishment. Bad medical care had led to unnecessary deaths in California prisons. In 2006, he appointed Robert Sillen as receiver to take over the health care system of the California Department of Corrections and Rehabilitation; he replaced Sillen with J. Clark Kelso in 2008.