Routine Medical Judgment Does Not Violate the Eighth Amendment: Denial of Non-Emergency MRI Is Not Deliberate Indifference

Introduction

In Wright v. Martin, No. 23-7762-pr (2d Cir. Apr. 8, 2025), the Second Circuit considered whether prison medical staff’s decision not to order an MRI for an inmate’s chronic abdominal pain rose to the level of “deliberate indifference” in violation of the Eighth Amendment. Plaintiff-appellant Ian Wright, a former inmate at Corrigan-Radgowski Correctional Center, sued under 42 U.S.C. § 1983, alleging that Dr. Ingrid Feder, Health Service Coordinator Janine Brennan, and other officials were indifferent to his serious medical needs by delaying or refusing diagnostic imaging. The District Court granted summary judgment for the defendants—first for failure to exhaust administrative remedies under the PLRA, and ultimately on the merits. Wright appealed, challenging both the exhaustion ruling and the substantive finding that declining an MRI was a permissible exercise of medical judgment. The Second Circuit affirmed on the merits.

Summary of the Judgment

The Court of Appeals affirmed the District Court’s grant of summary judgment to the defendants. Although Wright claimed he had exhausted all available administrative remedies or was excused from doing so, the Second Circuit bypassed that issue, concluding that even if exhaustion were satisfied, no reasonable jury could find deliberate indifference. The undisputed medical records showed that Wright received ongoing care, including examinations, X-rays, heartburn medication, and laxatives. Dr. Feder and Brennan reasonably determined an MRI was not clinically indicated in the absence of emergent symptoms. As a matter of law, a difference of medical opinion—here, choosing medication over imaging—does not satisfy the subjective “deliberate indifference” standard under the Eighth Amendment.

Analysis

Precedents Cited

Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a): exhaustion requirement.
Garcia v. Heath, 74 F.4th 44 (2d Cir. 2023) and Johnston v. Maha, 460 F. App’x 11 (2d Cir. 2012): defendants bear the burden to prove exhaustion.
Estelle v. Gamble, 429 U.S. 97 (1976): deliberate indifference test for inadequate medical care.
Farmer v. Brennan, 511 U.S. 825 (1994): subjective prong requires conscious disregard of a substantial risk.
Chance v. Armstrong, 143 F.3d 698 (2d Cir. 1998): disagreement over treatment is not per se Eighth Amendment violation.
Hathaway v. Coughlin, 37 F.3d 63 (2d Cir. 1994): medical care obligations under the Eighth Amendment.
Hill v. Curcione, 657 F.3d 116 (2d Cir. 2011): malpractice vs. culpable recklessness distinction.
Smalls v. Wright, 807 F. App’x 124 (2d Cir. 2020) and Tolliver v. Sidorowicz, 714 F. App’x 73 (2d Cir. 2018): declining imaging in favor of conservative treatment is medical judgment.
Nat’l R.R. Passenger Corp. v. McDonald, 779 F.3d 97 (2d Cir. 2015): appellate affirmance on any ground supported by the record.

Legal Reasoning

The Court applied de novo review to the summary judgment record. Under Rule 56, when evidence viewed in the light most favorable to Wright presented no genuine dispute of material fact, the defendants were entitled to judgment as a matter of law. The Eighth Amendment requires a two-pronged showing for a medical-care claim: (1) an objectively serious medical need; and (2) a defendant’s subjective deliberate indifference—knowing and disregarding a substantial risk of harm (Farmer).

Although chronic abdominal pain may satisfy the objective prong, Wright offered no evidence that Dr. Feder or Brennan consciously disregarded a risk of serious harm. The record demonstrated routine care: a back X-ray, prescription of antacids, sick-call visits, and a referral system modified by COVID-19 protocols. The decision not to order an MRI was based on the absence of acute red-flag symptoms (e.g., sudden onset constant pain, weight loss). Such medical judgments—even if later proven incorrect—do not constitute “cruel and unusual punishment” (Estelle) absent evidence of recklessness or purposeful denial of care.

Wright’s citation of Mallet v. NYSDOCCS, 126 F.4th 125 (2d Cir. 2025), was unavailing because there, unlike here, the complaint alleged both awareness of hallmark cancer symptoms and conscious choice of an inferior treatment plan. No similar inference could be drawn from Wright’s intermittent pain complaints and standard conservative treatment.

Impact

Wright v. Martin underscores the boundary between disagreement over prison medical treatment and constitutional deliberate indifference. Key effects include:

Clarifying that routine diagnostic decisions—such as deferring non-urgent imaging—are matters of professional medical judgment, not Eighth Amendment violations.
Reaffirming defendants’ burden to prove no genuine exhaustion dispute, but emphasizing that courts may affirm on the merits regardless of exhaustion arguments.
Providing guidance to lower courts on applying the subjective prong: intentional or reckless denial of clearly indicated care, not mere delays or conservative treatment choices.
Potentially reducing meritless prison medical claims based on differences in treatment philosophy rather than on proof of official indifference to known risks.

Complex Concepts Simplified

Deliberate Indifference: Requires proof that a prison official knew of and intentionally ignored a substantial risk to inmate health. Negligence or malpractice alone is insufficient.
Objective vs. Subjective Prong: The illness must be serious (objective), and the official must act with culpable intent or recklessness (subjective).
PLRA Exhaustion: Prisoners must use all available administrative grievance steps before suing. Defendants must prove the prisoner failed to exhaust.
Summary Judgment: If no factual dispute exists on an element essential to the claim, the court can decide the issue as a matter of law without a jury.

Conclusion

Wright v. Martin establishes that the choice to pursue conservative treatment over non-emergency diagnostic imaging does not, by itself, constitute Eighth Amendment deliberate indifference. Prison medical staff remain free to exercise professional judgment so long as they do not recklessly ignore an inmate’s clearly emergent or serious condition. This decision refines the contours of prisoner medical-care claims, reinforcing that only intentional or consciously reckless denials of clinically indicated care violate the Eighth Amendment.