Introduction

Wright v. Martin is a 2025 decision of the United States Court of Appeals for the Second Circuit addressing whether the refusal to order an MRI scan for a prisoner’s chronic abdominal pain constitutes an Eighth Amendment violation. Plaintiff‐Appellant Ian Wright, a former inmate at Corrigan‐Radgowski Correctional Center, sued under 42 U.S.C. § 1983, claiming that medical staff—Dr. Ingrid Feder and Health Services Coordinator Janine Brennan—were deliberately indifferent to his serious medical needs by denying diagnostic imaging. The district court granted summary judgment in favor of the defendants on exhaustion grounds and, alternatively, on the merits. On appeal, the Second Circuit assumed, without deciding, that Wright exhausted his administrative remedies but affirmed summary judgment for the defendants, holding that the decision not to order an MRI was a permissible exercise of medical judgment rather than deliberate indifference.

Summary of the Judgment

On April 8, 2025, a three‐judge panel of the Second Circuit unanimously affirmed the district court’s summary judgment. The panel:

• Noted that Wright alleged chronic abdominal pain and sought an MRI;
• Explained that summary orders do not carry precedential effect but can be cited under certain rules;
• Assumed arguendo that Wright had exhausted his administrative remedies under the Prison Litigation Reform Act (PLRA);
• Evaluated the Eighth Amendment deliberate indifference claim de novo;
• Concluded that refusing to order an MRI and choosing to treat with medication was a matter of medical judgment;
• Held that mere disagreement over medical treatment does not rise to constitutional deliberate indifference absent culpable recklessness;
• Found no evidence that Dr. Feder or Brennan knowingly disregarded a substantial risk of serious harm;
• Affirmed summary judgment for the defendants on the merits.

Analysis

Precedents Cited

• PLRA Exhaustion  Garcia v. Heath, 74 F.4th 44 (2d Cir. 2023) – burden on defendants to show failure to exhaust.  Johnston v. Maha, 460 F. App’x 11 (2d Cir. 2012) – same principle.
• Exhaustion Is Not Jurisdictional  Nat’l R.R. Passenger Corp. v. McDonald, 779 F.3d 97 (2d Cir. 2015);  Richardson v. Goord, 347 F.3d 431 (2d Cir. 2003) – PLRA exhaustion is a “claim‐processing” rule.
• Eighth Amendment Standard  Estelle v. Gamble, 429 U.S. 97 (1976) – deliberate indifference to serious medical needs; classic examples of medical judgment are non‐actionable.  Farmer v. Brennan, 511 U.S. 825 (1994) – objective and subjective prongs.  Chance v. Armstrong, 143 F.3d 698 (2d Cir. 1998) – disagreement over treatment does not create a constitutional claim; conscious choice of“easier” treatment can violate Eighth Amendment.  Hill v. Curcione, 657 F.3d 116 (2d Cir. 2011) – medical malpractice only violates Eighth Amendment if it shows culpable recklessness.  Hathaway v. Coughlin, 37 F.3d 63 (2d Cir. 1994) – medical care standard.
• Recent Medical Treatment Cases  Collymore v. Myers, 74 F.4th 22 (2d Cir. 2023) – deliberate indifference elements.  Smalls v. Wright, 807 F. App’x 124 (2d Cir. 2020) – decision not to order MRI is medical judgment.  Tolliver v. Sidorowicz, 714 F. App’x 73 (2d Cir. 2018) – no Eighth Amendment violation in choosing compression stocking and ibuprofen over MRI.  Tangreti v. Bachmann, 983 F.3d 609 (2d Cir. 2020) – subjective knowledge requirement.  Matzell v. Annucci, 64 F.4th 425 (2d Cir. 2023) – objective/subjective prongs delineated.

Legal Reasoning

The Second Circuit applied de novo review to the summary judgment record. Under Rule 56(a), summary judgment is proper if no genuine factual dispute exists and the movant is entitled to judgment as a matter of law. The Court:

1. Assumed exhaustion to reach the merits;
2. Outlined the Eighth Amendment’s two‐pronged deliberate indifference test:
   • Objective prong: serious medical need;
   • Subjective prong: official’s knowledge of and disregard for a substantial risk.
3. Reviewed Wright’s medical record from February to September 2020:
   • February 2020: nurse visit for back pain; x-ray ordered;
   • February 14, 2020: plaintiff on sick call list;
   • February 26, 2020: Dr. Feder prescribes antacid for abdominal pain;
   • April 2020: grievance denied by Brennan – “no clinical indication for MRI”;
   • May & August 2020: further visits; Dr. Feder reaffirms no MRI needed;
   • COVID-19 imaging restrictions explained delay;
   • September 2020: visits for vital-sign refusal and constipation, no MRI ordered;
   • October 2020: transfer to Cheshire Correctional Institution.
4. Held that refusing an MRI in favor of medication was a matter of medical judgment:
5. Applied Estelle’s teaching that disagreements over diagnostic testing do not, by themselves, prove deliberate indifference;
6. Found no evidence that the defendants consciously disregarded a known, substantial risk of harm.

Impact

Wright v. Martin reinforces the principle that prison medical judgments—such as opting for medication or observation over advanced imaging—generally fall outside the Eighth Amendment’s deliberate‐indifference prohibition. The decision:

• Clarifies the high threshold for establishing subjective culpability;
• Emphasizes deference to professional medical judgment in correctional settings;
• Illustrates how PLRA exhaustion disputes may be bypassed if the merits are plainly resolved;
• Will guide lower courts in evaluating Eighth Amendment claims based on diagnostic decisions;
• May reduce inmate litigation over routine diagnostic choices absent emergency indicators.

Complex Concepts Simplified

• Deliberate Indifference: A prison official’s knowing disregard of a substantial risk to inmate health. It has an objective part (serious medical need) and a subjective part (official’s state of mind).
• Eighth Amendment: Prohibits “cruel and unusual punishments.” Its medical‐care component bars deliberate indifference to serious needs.
• PLRA Exhaustion: Inmates must use prison grievance procedures before suing. Defendants bear the burden to prove failure to exhaust.
• Summary Judgment: A court‐ruled judgment without trial when there is no genuine dispute over material facts.
• Medical Judgment vs. Constitutional Violation: Disagreements over treatment (e.g., MRI vs. medication) are medical judgments, not constitutional violations, unless there is evidence of reckless disregard.

Conclusion

Wright v. Martin confirms that, under the Eighth Amendment, defendants are entitled to broad latitude in choosing diagnostic and therapeutic strategies. The decision not to order an MRI, in the absence of red‐flag symptoms or emergent concerns, is a prototypical medical judgment and does not, by itself, constitute deliberate indifference. This ruling underscores the judiciary’s deference to professional medical decisions in correctional settings and clarifies the contours of inmate medical‐care litigation under 42 U.S.C. § 1983.