Summary
The Supreme Court held that a physician contracted by a state to provide medical services to prison inmates acts under color of state law when treating an inmate for purposes of 42 U.S.C. § 1983. The Court explained that the physician's function within the state prison system, rather than the precise terms of his employment, determines whether his conduct is fairly attributable to the State. The Court reversed the Fourth Circuit's judgment and remanded for further proceedings concerning the inmate's deliberate-indifference claim.
Topics
Practice areas
Questions Presented
- Whether a physician who provides medical services to state prisoners under a contract with the State acts under color of state law for purposes of 42 U.S.C. § 1983.
- Whether the Supreme Court should decide at that stage whether West's allegations established deliberate indifference to a serious medical need under the Eighth Amendment.
Holdings
- A physician employed by the State, including one employed under a part-time contractual arrangement, acts under color of state law when providing medical treatment to state prison inmates. The physician's function within the state system, rather than the precise terms of employment, controls the state-action analysis.
- The Court declined to decide in the first instance whether West had adequately alleged or shown deliberate indifference to a serious medical need because no court had undertaken the necessary factfinding and the issue was not necessary to resolve the state-action question.
Key quotations
“It is the physician's function within the state system, not the precise terms of his employment, that determines whether his actions can fairly be attributed to the State.” (55-56)
“Contracting out prison medical care does not relieve the State of its constitutional duty to provide adequate medical treatment to those in its custody, and it does not deprive the State's prisoners of the means to vindicate their Eighth Amendment rights.” (56)
“It is the physician's function while working for the State, not the amount of time he spends in performance of those duties or the fact that he may be employed by others to perform similar duties, that determines whether he is acting under color of state law.” (57)
Factual background
Quincy West, a close-custody North Carolina prisoner, tore his Achilles tendon while incarcerated and was referred to Central Prison Hospital. Samuel Atkins, a private physician under contract with North Carolina, treated West over several months but allegedly failed to schedule necessary surgery and discharged him while his ankle remained swollen, painful, and impaired. Because of his custody status, West could not choose an independent physician or obtain medical care outside the state prison system.
Procedural history
West filed a pro se § 1983 action in the Eastern District of North Carolina alleging that Atkins was deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. The District Court granted Atkins summary judgment on the ground that a contract physician did not act under color of state law. A Fourth Circuit panel vacated and remanded, but the en banc court affirmed the dismissal, relying on Calvert v. Sharp. The Supreme Court granted certiorari to resolve a conflict among the Courts of Appeals, reversed, and remanded for further proceedings.
Remand instructions
The case was remanded to the lower courts for further proceedings consistent with the opinion, including consideration of whether West could establish deliberate indifference to a serious medical need under the Eighth Amendment.