Ray v. Wexford Health Sources, Inc.
2013 U.S. App. LEXIS 2601
| 7th Cir. | 2013Background
- Hoyt Ray, an inmate, alleges shoulder pain and seeks MRI diagnosis, claiming it would guide treatment.
- Dr. Vipin K. Shah treated Ray for arthritis-like symptoms and did not order an MRI, which Ray contends was inappropriate.
- Ray sues Shah under 42 U.S.C. § 1983 for cruel and unusual punishment, arguing deliberate indifference to a serious medical need.
- The district court granted summary judgment for Shah, finding no deliberate indifference regardless of MRI appropriateness.
- Ray also sues Wexford Health Sources, alleging a no-MRI policy caused constitutional harm, but he fails to show actionable injury from any policy.
- The court discusses Ray’s request for counsel and notes the absence of statutory appointment of counsel in § 1983 cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Shah’s MRI decision violates the Eighth Amendment | Ray argues Shah’s refusal to MRI shows deliberate indifference. | Shah treats arthritis; MRI not required and not deliberately indifferent. | No; Ray fails objective component; no deliberate indifference. |
| Whether Wexford's policy (no-MRI) caused a cognizable constitutional injury | Ray contends policy prevented MRI and harmed him. | Policy existence not shown to cause injury; care was medically appropriate. | No actionable injury; policy not proven to cause constitutional violation. |
| Whether Ray’s request for court-appointed counsel should be granted or remanded | Ray seeks appointment of counsel to assist; form misleads | Appointment is not statutory; no remand necessary | No remand; district court appropriately handled under existing framework. |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (1994) (establishes objective/subjective components of Eighth Amendment deliberate indifference)
- Estelle v. Gamble, 429 U.S. 97 (1976) (medical negligence and needs in prison context not automatically actionable)
- Monell v. New York City Dep’t of Social Services, 436 U.S. 658 (1978) (local government liability requires policy and practice causing harm)
- Mallard v. United States District Court for Southern District of Iowa, 490 U.S. 296 (1989) (no statutory right to appointment of counsel; volunteer assistance only)
- Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (en banc; standards for seeking counsel in §1983 actions)