DeAngelis v. Warden
Allegations that corrections officials refused to order magnetic resonance imaging or to approve a soft mattress for an inmate who allegedly suffers from severe back pain may be insufficient to prove deliberate indifference to a serious medical condition, in violation of the Eighth Amendment. The plaintiff inmate, Jeffrey DeAngelis, filed a petition for a writ of habeas corpus and alleged that the defendant corrections officials were deliberately indifferent to a serious medical condition. Allegedly, although DeAngelis has suffered from severe, constant lower back pain for four years, corrections officials refuse to approve magnetic resonance imaging or a soft mattress. Medical records established that in May 2012 Dr. Farinella examined the petitioner and ordered an X-ray, which did not disclose significant neurological or functional problems, such as nerve root impingement or a bulging disc. In a follow-up examination in October 2012, Dr. Ruiz did not find signs of muscle atrophy or reflex impairment when he examined the petitioner. Dr. Ruiz diagnosed the petitioner with degenerative joint disease, as opposed to a neurological defect. Dr. Ruiz prescribed pain medicine and exercise, to strengthen the petitioner's back. Dr. Ruiz considered the petitioner's requests for magnetic resonance imaging and a soft mattress and decided that they were not required. To prevail, the petitioner must prove that the defendants were deliberately indifferent to a serious medical condition. Disagreement about the type of medical treatment provided is insufficient to meet that standard. "No evidence was adduced," wrote the court, "that the medical care provided was substandard." The court denied the petition for a writ of habeas corpus.