Jane Doe v. Mountain View Hospital, LLC; Idaho Falls Community Hospital, LLC

Summary

The United States District Court for the District of Idaho addresses Plaintiff Jane Doe’s motion for leave to amend and for reconsideration, along with former defendants Brandon Bloxham and Justin Thompson’s motion to intervene. The court grants limited intervention for purposes of opposing the amendment and reconsideration motions, but denies Plaintiff’s motion to amend to add a 42 U.S.C. § 1983 claim and to reconsider dismissal of state tort claims. The court concludes that the proposed § 1983 claim is futile because the alleged conduct by the private hospital and physicians is not fairly attributable to the state.

Holdings

1. Former defendants who would be directly implicated by proposed new or renewed claims may intervene for the limited purpose of opposing a motion to amend and a motion for reconsideration when the intervention is timely, their interests are significantly protectable and may be impaired, existing parties may not adequately represent those interests, and the proposed claims share common questions of law or fact.
2. Leave to amend may be denied as futile where the proposed § 1983 claim alleges constitutional deprivations caused only by private conduct and fails to plausibly allege that the defendants acted under color of state law or that their conduct was fairly attributable to the State.
3. Reconsideration was unwarranted because Plaintiff did not establish newly discovered evidence, clear error, or an intervening change in controlling law, and the proposed § 1983 amendment was denied.

Questions Presented

1. Whether Brandon Bloxham and Justin Thompson satisfied the requirements for intervention as of right or permissive intervention under Federal Rule of Civil Procedure 24.
2. Whether leave to amend should be denied as futile because the proposed 42 U.S.C. § 1983 claim did not plausibly allege that the defendants acted under color of state law.
3. Whether reconsideration of the dismissal of the state-law tort claims was warranted under Federal Rule of Civil Procedure 59(e).

Disposition

other