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Bain v. Atkins

Supreme Court of United States
487 U.S. 42 (1988)
ELI5:

Rule of Law:

A physician who is under contract with the state to provide medical services to inmates at a state prison hospital acts 'under color of state law' for purposes of a 42 U.S.C. § 1983 claim when treating an inmate.


Facts:

  • Quincy West, an inmate at a North Carolina state prison, tore his Achilles tendon while playing volleyball.
  • West was transferred to the state's Central Prison Hospital for specialized orthopedic care.
  • The state contracted with Dr. Samuel Atkins, a private physician, to provide part-time orthopedic services at the prison hospital twice a week.
  • Dr. Atkins treated West's injury over several months by placing his leg in a series of casts.
  • West alleged that Dr. Atkins acknowledged surgery was necessary but refused to schedule it.
  • West further alleged that Dr. Atkins discharged him while his ankle was still swollen, painful, and his movement was impeded.
  • As a prisoner, West was not free to seek medical treatment from a physician of his own choosing.

Procedural Posture:

  • Quincy West filed a pro se lawsuit under 42 U.S.C. § 1983 against Dr. Samuel Atkins in the U.S. District Court for the Eastern District of North Carolina.
  • The District Court granted summary judgment for Dr. Atkins, concluding he was not acting under color of state law.
  • West, as appellant, appealed to the U.S. Court of Appeals for the Fourth Circuit.
  • A three-judge panel of the Fourth Circuit vacated the District Court's judgment and remanded the case.
  • The Fourth Circuit then granted an en banc rehearing of the case.
  • The en banc Fourth Circuit, with Dr. Atkins as appellee, affirmed the District Court's dismissal, holding that a professional acting with traditional professional discretion does not act under color of state law.
  • The U.S. Supreme Court granted West's petition for a writ of certiorari.

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Issue:

Does a private physician, who is under contract with the state to provide part-time medical services to inmates at a state-prison hospital, act 'under color of state law' within the meaning of 42 U.S.C. § 1983 when treating an inmate's injury?


Opinions:

Majority - Justice Blackmun

Yes. A physician employed by the state to provide medical services to prison inmates acts under color of state law for purposes of § 1983. The state has a constitutional obligation under the Eighth Amendment to provide adequate medical care to those it incarcerates. By hiring Dr. Atkins to fulfill this duty, the state delegated its constitutional responsibility to him. It is the physician's function within the state system, not the precise terms of his employment (e.g., contract employee vs. full-time staff), that determines whether his actions can be fairly attributed to the state. Unlike the public defender in Polk County v. Dodson, whose professional duty is to act as an adversary to the state, a prison physician's role is cooperative and in furtherance of the state's mission to provide care. Therefore, when Dr. Atkins treated West, he was exercising power made possible by the state and was 'clothed with the authority of state law.'


Concurring - Justice Scalia

Yes. The respondent acted under color of state law for purposes of § 1983. However, the proper constitutional basis for the claim is likely the Fourteenth Amendment's Due Process Clause, not the Eighth Amendment's prohibition on cruel and unusual punishment. A physician who lacks supervisory or penological duties cannot inflict 'punishment' in the Eighth Amendment sense. Rather, a physician acting on behalf of the state who, through deliberate indifference, causes physical harm to a person involuntarily in state custody deprives that person of liberty without due process of law.



Analysis:

This case establishes a functional approach to the 'under color of state law' analysis for private actors performing government duties. It clarifies that a state cannot avoid § 1983 liability by outsourcing its constitutional obligations, such as providing medical care to prisoners. The decision ensures that individuals whose rights are violated by these private actors have a remedy under federal civil rights law. This precedent is crucial in an era of increasing privatization of government services, affirming that the substance of the function performed, not the employment status of the actor, is the key determinant of state action.

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