Medical Judgment in Diagnostic Testing and the Eighth Amendment: Wright v. Martin

1. Introduction

Wright v. Martin (23-7762-pr) is a summary order issued by the United States Court of Appeals for the Second Circuit on April 8, 2025. The appellant, Ian Wright, a former inmate at Corrigan-Radgowski Correctional Center, alleged that prison medical staff—primarily Dr. Ingrid Feder and Janine Brennan—were deliberately indifferent to his serious medical needs when they declined to order abdominal imaging (an MRI) for his chronic pain. Wright sued under 42 U.S.C. § 1983, claiming an Eighth Amendment violation. The district court granted summary judgment for the defendants on the basis of Wright’s failure to exhaust administrative remedies under the Prison Litigation Reform Act (PLRA) and, alternatively, on the merits of the Eighth Amendment claim. Wright appealed and challenged both the exhaustion ruling and the merits decision. The Second Circuit affirmed summary judgment on the merits, holding that the decision not to order an MRI was a matter of medical judgment, not deliberate indifference.

2. Summary of the Judgment

The Second Circuit assumed, without deciding, that Wright had properly exhausted his administrative remedies under the PLRA.
The court then examined Wright’s Eighth Amendment claim de novo and held that a disagreement over diagnostic testing (the choice not to order an MRI) is a medical judgment that does not satisfy the subjective element of “deliberate indifference.”
Because the evidence showed ongoing treatment—medication management, x-rays, nurse visits—and no signs of emergent or life-threatening conditions, no rational jury could infer that Dr. Feder or Brennan consciously disregarded a substantial risk to Wright’s health.
Accordingly, summary judgment for the defendants was affirmed, and the Eighth Amendment claim was dismissed.

3. Analysis

3.1. Precedents Cited

The court’s decision rests on well-established Eighth Amendment and civil procedure precedents:

Estelle v. Gamble (429 U.S. 97, 1976): Defined “deliberate indifference” to serious medical needs under the Eighth Amendment.
Farmer v. Brennan (511 U.S. 825, 1994): Established that deliberate indifference requires subjective knowledge and disregard of a substantial risk to inmate health.
Chance v. Armstrong (143 F.3d 698, 2d Cir. 1998): Held that mere disagreement over treatment is not a constitutional violation but recognized that an easier, less efficacious treatment could, in rare cases, show deliberate indifference.
Hill v. Curcione (657 F.3d 116, 2d Cir. 2011): Clarified that medical malpractice must involve culpable recklessness to rise to the level of deliberate indifference.
Smalls v. Wright (807 F. App’x 124, 2d Cir. 2020) and Tolliver v. Sidorowicz (714 F. App’x 73, 2d Cir. 2018): Both reaffirm that decisions not to order imaging or specialist referrals are matters of medical judgment.
Nat’l R.R. Passenger Corp. v. McDonald (779 F.3d 97, 2d Cir. 2015): Permitted affirmance on any basis supported by the record, even if not relied on below.
PLRA exhaustion cases such as Garcia v. Heath (74 F.4th 44, 2d Cir. 2023) and Johnston v. Maha (460 F. App’x 11, 2d Cir. 2012): Place the burden on defendants to prove non-exhaustion, but exhaustion is not jurisdictional (Richardson v. Goord, 347 F.3d 431, 2d Cir. 2003).

3.2. Legal Reasoning

The court’s legal analysis proceeded in two steps:

Exhaustion of Administrative Remedies: The district court found Wright failed to exhaust most grievances. Although Wright submitted sworn testimony and grievance forms, the Second Circuit did not need to resolve exhaustion because it affirmed on the merits.
Merits of the Eighth Amendment Claim:
- Objective Prong: Wright’s chronic abdominal pain could qualify as a serious medical need.
- Subjective Prong: The critical inquiry was whether Dr. Feder and Brennan “kn[ew] of and disregard[ed] an excessive risk to inmate health.” There was no evidence they failed to act or consciously dismissed an emergency. Instead, they prescribed medication, ordered x-rays, monitored his condition, and concluded imaging was not clinically indicated absent red-flag symptoms (e.g., weight loss, constant severe pain).
- Medical Judgment: The choice to manage the condition with acid-blocking medication and Tylenol, rather than immediately ordering an MRI, was a classic exercise of medical discretion. Absent proof of culpable recklessness—such as knowing that medication was ineffective yet persisting in it to save effort—there is no constitutional violation.

3.3. Impact

Wright v. Martin underscores several important points for future Eighth Amendment medical claims:

Prisoners challenging denial of diagnostic tests must show more than a difference of medical opinion; they must present evidence of conscious disregard for a known risk.
Defense counsel may seek summary judgment on the merits even when exhaustion disputes remain, provided the record clearly shows no genuine issue of deliberate indifference.
Medical providers in correctional settings gain reassurance that thoughtful, documented treatment plans and rational explanations for not pursuing certain tests will ordinarily defeat Eighth Amendment claims.
The decision reaffirms that PLRA exhaustion, while mandatory, can be bypassed on appeal when the court can dispose of the case on other grounds.

4. Complex Concepts Simplified

Deliberate Indifference: A conscious choice to ignore a substantial risk to a prisoner’s health or safety. Mere negligence or difference of opinion about treatment does not qualify.
Objective vs. Subjective Prongs: Objectively, the condition must be serious. Subjectively, the official must know about the risk and choose to disregard it.
Medical Judgment: Decisions about which tests to order and which medications to prescribe are typically medical judgments, not constitutional questions.
PLRA Exhaustion: Before suing, inmates must use the prison’s grievance process. Defendants bear the burden of proving that an inmate did not complete all required steps.
Summary Judgment: A procedural device that ends a case when there is no real dispute about material facts and the moving party is entitled to win as a matter of law.

5. Conclusion

Wright v. Martin reaffirms the principle that, under the Eighth Amendment, a difference in medical opinion—especially regarding the timing or necessity of diagnostic imaging—does not constitute “cruel and unusual punishment.” The case demonstrates the importance of clear medical records, reasoned explanations for treatment choices, and the viability of summary judgment when no triable issue of deliberate indifference exists. For prisoners, it emphasizes that claims challenging mere diagnostic discretion face a high bar: proof of culpable recklessness or conscious risk-taking by medical personnel. For courts and practitioners, it showcases a pragmatic approach to disposing of meritless Eighth Amendment claims through summary disposition.