Adams. v. Jones, 577 F. App'x 778

Adams, a state prisoner, sues under 42 U.S.C. § 1983 for alleged inadequate medical care and retaliation in a transfer after filing suit.
In 2010 Adams reinjures his left foot; medical evaluations lead to a diagnosis of arthritis with no further procedures recommended.
In 2011 Adams is transferred following backhoe-related incidents; he amends his complaint to add a retaliation claim.
The district court granted summary judgment on the transfer-retaliation claim for failure to exhaust, and granted summary judgment on the medical claim on the merits.
Adams sought discovery and a physical exam and challenged denial of judgment on the pleadings; the district court denied these motions and the appeal follows.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Adams stated a viable deliberate-indifference claim	Adams contends doctors were negligent and ignored records.	Negligence in diagnosis/treatment does not equal deliberate indifference.	No Eighth Amendment violation; summary judgment proper.
Whether Adams exhausted administrative remedies for the transfer claim	Grievances were filed and exhausted through prison channels.	Adams failed to properly exhaust under prison grievance procedures.	Adams did not exhaust; transfer claim barred.
Whether the district court abused its discretion in discovery ruling	Documents regarding the transfer should have been produced mandatorily.	Documents already provided; no abuse of discretion.	No abuse of discretion; discovery affirmed.
Whether the district court erred in denying a physical examination and judgment on the pleadings	Physical exam was warranted; judgment on pleadings should be granted.	Physical condition not in controversy; no basis for 12(c); denial proper.	No abuse; rulings affirmed.

Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment requires both objective and subjective components)
Estelle v. Gamble, 429 U.S. 97 (1976) (medical negligence alone not a constitutional violation)
Sealock v. Colorado, 218 F.3d 1209 (10th Cir. 2000) (deliberate indifference standard and exhaustion discussion)
Woodford v. Ngo, 548 U.S. 81 (2006) (exhaustion requirements and administrative remedies)
Little v. Jones, 607 F.3d 1245 (10th Cir. 2010) (when prison actions hinder access, exhaustion may be excused)
Callahan v. Poppell, 471 F.3d 1155 (10th Cir. 2006) (difference of opinion in medical treatment is not a constitutional violation)
Park Univ. Enters. v. Am. Cas. Co., 442 F.3d 1239 (10th Cir. 2006) (judgment on the pleadings standard and review)