15 N.Y.3d 275 (2010)
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A prison inmate is not entitled to experimental medical treatment, even when recommended by multiple doctors, if the treatment is unproven in long-term studies and not yet approved by the FDA, and the prison’s denial is rationally based.
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Summary
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Robert Wooley, a prison inmate with hepatitis C, sought low-dose maintenance pegylated interferon treatment after completing two standard courses of interferon/ribavirin therapy. Multiple doctors recommended the treatment, but the Department of Correctional Services (DOCS) denied it because it was not FDA-approved and lacked proven long-term benefits. Wooley filed an Article 78 proceeding, arguing the denial was arbitrary, capricious, and violated his Eighth Amendment rights. The New York Court of Appeals affirmed the lower courts’ dismissal, holding that DOCS’s decision was rationally based and did not constitute deliberate indifference to Wooley’s medical needs. The court deferred to DOCS’s judgment, emphasizing that the requested treatment was experimental and lacked established efficacy.
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Facts
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Robert Wooley, incarcerated since the 1980s, was diagnosed with hepatitis C. He received interferon/ribavirin treatment in 2001, achieving undetectable viral load. After a relapse, he was re-treated with pegylated interferon/ribavirin. Nearing completion of the second treatment, several doctors recommended low-dose maintenance pegylated interferon to prevent cirrhosis. DOCS, through Chief Medical Officer Dr. Wright, denied the request, citing the lack of published studies supporting the treatment’s value and its experimental nature. A liver biopsy showed mild inflammation but no cirrhosis.
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Procedural History
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Wooley filed a grievance, which DOCS denied. He then commenced a CPLR Article 78 proceeding in Supreme Court, alleging the denial was arbitrary, capricious, and violated the Eighth Amendment. Supreme Court denied the petition. The Appellate Division affirmed. The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
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Issue(s)
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1. Whether DOCS’s denial of low-dose maintenance pegylated interferon treatment to Wooley was arbitrary and capricious.
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2. Whether DOCS’s denial of the requested treatment constituted cruel and unusual punishment in violation of the Eighth Amendment.
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Holding
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1. No, because DOCS’s determination had a rational basis, as the requested treatment was unproven in long-term studies and not yet FDA-approved.
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2. No, because the denial did not constitute deliberate indifference to Wooley’s serious medical needs, as Wooley received two courses of standard treatment, and the requested maintenance treatment was experimental.
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Court’s Reasoning
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The Court of Appeals held that DOCS’s decision had a rational basis. The court stated, “If we conclude ‘that the determination is supported by a rational basis, [we] must sustain the determination even if [this C]ourt concludes that it would have reached a different result than the one reached by the agency.’” The court deferred to DOCS’s judgment, highlighting the experimental nature and lack of FDA approval for the requested treatment. The court emphasized that the determination was made after considering the specific facts of Wooley’s case, as evidenced by Dr. Wright’s reasoning that no published studies supported the treatment. The court declined to weigh conflicting medical studies, deferring to DOCS’s determination that the lack of documented success constituted a rational basis for denial.
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Regarding the Eighth Amendment claim, the court applied the “deliberate indifference” standard, requiring both objective (sufficiently serious deprivation of medical care) and subjective (culpable state of mind) components. The court noted that a violation of the Eighth Amendment can be proven only if an inmate can demonstrate that prison officials have acted with