Wideman v. Shallowford Community Hospital, Inc.
56 U.S.L.W. 2151, 826 F.2d 1030 (1987)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment does not create a general affirmative right to government-provided medical services. A constitutional duty for a state to provide care arises only when a 'special relationship' is formed, which requires the state to exercise a significant degree of custody or control that restrains an individual's freedom and impairs their ability to act on their own behalf.
Facts:
- Toni Wideman, who was four months pregnant, began experiencing abdominal pain.
- Her obstetrician, Dr. John Ramsey, instructed her to come immediately to Piedmont Hospital.
- Wideman called 911 in DeKalb County and requested an ambulance to take her to Piedmont Hospital.
- DeKalb County Emergency Medical Service (EMS) employees responded to the call.
- Wideman informed the EMS employees that her doctor was waiting for her at Piedmont Hospital.
- The EMS employees refused to take Wideman to Piedmont and, against her wishes, transported her to Shallowford Community Hospital.
- After a substantial delay at Shallowford, Wideman was transferred to Piedmont Hospital.
- By the time she arrived at Piedmont, Dr. Ramsey was unable to stop her premature labor, and her baby died four hours after birth.
Procedural Posture:
- Toni Wideman and her husband filed a lawsuit in U.S. District Court against DeKalb County, Shallowford Hospital, and three EMS employees under 42 U.S.C. § 1983 and state tort law.
- The governmental defendants and Shallowford Hospital moved for summary judgment on the federal claims.
- The plaintiffs moved to amend their complaint and to compel discovery.
- The district court denied the plaintiffs' motions and granted summary judgment in favor of all defendants on the federal claims.
- The plaintiffs (appellants) appealed the district court's grant of summary judgment to the U.S. Court of Appeals for the Eleventh Circuit.
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Issue:
Does a county’s alleged policy of using its emergency medical vehicles to transport patients only to certain hospitals, and not to the hospital of the patient's choice, violate a constitutional right protected under 42 U.S.C. § 1983?
Opinions:
Majority - Hill, Circuit Judge
No, the county's alleged policy does not violate a constitutional right because the Constitution does not impose a general affirmative duty on the government to provide medical services. The court reasoned that § 1983 provides a remedy for the deprivation of existing federal rights but does not create substantive rights itself. The Due Process Clause protects 'negative liberties'—an individual's right to be free from arbitrary state action—rather than 'positive liberties,' which would entitle individuals to government services. While a constitutional duty to provide care can arise from a 'special relationship' (e.g., with prisoners or arrestees), such a relationship is created only when the state exercises significant custody, coercion, or restraint, thereby impairing an individual's ability to care for themselves. In this case, no special relationship existed because DeKalb County did not cause Ms. Wideman's medical emergency, nor did it coerce her into its ambulance; she entered it voluntarily. The fact that a government chooses to provide some service does not create a constitutional obligation to provide that service in a particular manner desired by a citizen. While the Widemans may have valid tort claims under state law, their situation does not rise to the level of a constitutional deprivation.
Analysis:
This decision reinforces the principle that the Due Process Clause primarily protects negative liberties, significantly limiting the ability to bring § 1983 claims against municipalities for inadequate provision of public services. It clarifies that the 'special relationship' doctrine, which creates an affirmative duty of care for the state, is narrowly construed and generally applies only in situations of custody or significant restraint, such as incarceration. This ruling channels claims based on the negligent performance of public services, like emergency medical transport, away from federal constitutional litigation and toward state tort law. Consequently, it protects government entities from federal liability for policy decisions about resource allocation in public safety services.
