Eighth Amendment Liability Limited: Discretionary Medical Judgment Does Not Constitute Deliberate Indifference

Introduction

Wright v. Martin, decided by the Second Circuit on April 8, 2025, involved a former Connecticut prison inmate, Ian Wright, who sued correctional medical staff under 42 U.S.C. § 1983 for alleged Eighth Amendment violations. Wright claimed that prison medical personnel, including Dr. Ingrid Feder and health‐services coordinator Janine Brennan, were deliberately indifferent to his serious medical needs by refusing to order diagnostic imaging (an MRI) for chronic abdominal pain. The district court granted summary judgment for the defendants on exhaustion and merits grounds; the court of appeals affirmed solely on the merits. This decision reaffirms that differences in medical judgment—even those with significant consequences—do not, without more, rise to the level of constitutional deliberate indifference.

Summary of the Judgment

The Second Circuit reviewed de novo the district court’s grant of summary judgment. It assumed arguendo that Wright had exhausted his administrative remedies under the Prison Litigation Reform Act (42 U.S.C. § 1997e(a)), but concluded that the record, viewed in the light most favorable to Wright, did not permit a reasonable jury to find that the defendants acted with the requisite “deliberate indifference.” Although Wright repeatedly requested an MRI for intermittent abdominal pain, the evidence showed:

Medical encounters over several months in 2020 in which nurses and Dr. Feder examined him, prescribed antacid medication and pain relief (Tylenol), and ordered X-rays (not an MRI) based on their clinical judgment;
Grievance responses by Brennan stating that there was “no clinical indication for MRI based on x-ray, lab work and history”; and
No facts suggesting that the defendants consciously disregarded an excessive risk to inmate health, as required by Farmer v. Brennan, 511 U.S. 825 (1994), and Estelle v. Gamble, 429 U.S. 97 (1976).

Because Wright’s allegations reflected a classic difference of medical opinion rather than culpable recklessness, summary judgment for the prison doctors and administrators was appropriate.

Analysis

1. Precedents Cited

Estelle v. Gamble, 429 U.S. 97 (1976) – established the Eighth Amendment standard for deliberate indifference to serious medical needs.
Farmer v. Brennan, 511 U.S. 825 (1994) – defined the subjective prong: conscious disregard of a known risk.
Chance v. Armstrong, 143 F.3d 698 (2d Cir. 1998) – held that mere disagreement over treatment does not create constitutional liability.
Hathaway v. Coughlin, 37 F.3d 63 (2d Cir. 1994) – applied the two‐prong Estelle/Farmer test in the prison medical context.
Hill v. Curcione, 657 F.3d 116 (2d Cir. 2011) – emphasized that malpractice, absent culpable recklessness, is not an Eighth Amendment violation.
Smalls v. Wright, 807 F. App’x 124 (2d Cir. 2020) – found no deliberate indifference where an MRI was declined in favor of less invasive treatment.
Tolliver v. Sidorowicz, 714 F. App’x 73 (2d Cir. 2018) – held that choosing compression stockings over MRI does not establish deliberate indifference.
Tangreti v. Bachmann, 983 F.3d 609 (2d Cir. 2020) – clarified that subjective knowledge and disregard of substantial risk are required.

2. Legal Reasoning

The court applied the settled two‐prong Eighth Amendment inquiry:

Objective prong: Was the alleged deprivation “sufficiently serious”? Wright’s chronic abdominal pain arguably met this requirement.
Subjective prong: Did the defendants “know of and disregard an excessive risk to inmate health or safety”? To establish this, Wright needed to show that Dr. Feder and Brennan were aware of facts suggesting a substantial risk and consciously disregarded it.

The court held that the choice not to order an MRI—based on X-ray results, lack of “hallmark symptoms” (sudden onset pain, weight loss, appetite loss), and a reasonable trial of medication—was a matter of medical judgment. Under Estelle and Chance, such judgments, even if later shown suboptimal, do not amount to deliberate indifference absent evidence that the defendants acted with culpable recklessness. No facts suggested that Dr. Feder or Brennan consciously chose an easier path while knowing that Wright faced a grave risk if not given an MRI.

3. Impact

The Second Circuit’s decision in Wright v. Martin reinforces several key points for future prison medical litigation:

Medical staff retain broad discretion to choose among diagnostic and therapeutic options without fear of per se Eighth Amendment liability.
The subjective prong remains a high bar: disagreement over treatment is insufficient; plaintiffs must show conscious disregard of a known, serious risk.
Prisoners’ burden to exhaust administrative remedies under the PLRA remains important, though not jurisdictional once met; but merits review may proceed even if exhaustion is disputed.
Defendants carry the burden at summary judgment to show no genuine issue of material fact on exhaustion and deliberate indifference.

Complex Concepts Simplified

Deliberate indifference: A legal term meaning a defendant must both know of and disregard a substantial risk of serious harm. It goes beyond negligence or disagreement over care.
Objective vs. subjective prongs: “Objective” asks if the medical need is serious; “subjective” asks if the defendant was actually aware of and consciously disregarded the risk.
Medical judgment: Decisions about diagnostic tests and treatment options are typically within a physician’s professional discretion and do not automatically trigger constitutional liability.
PLRA exhaustion: Prisoners must first use all available grievance procedures before suing, but failure to exhaust is an affirmative defense, not a jurisdictional threshold once met or waived.

Conclusion

Wright v. Martin clarifies that in the Eighth Amendment context, prison medical staff are not constitutionally liable simply because a diagnostic choice—such as forgoing an MRI—proves unfruitful. Plaintiffs must show more than a difference of medical opinion; they must demonstrate that prison doctors or administrators consciously disregarded a substantial risk of harm. This ruling thereby upholds the principle that constitutional deliberate indifference requires culpable mental state, preserving medical discretion while ensuring inmates’ serious needs remain protected under established precedent.