Source: cases/42usc1983/us-526-40-american-manufacturers-v-sullivan.case
Case source: https://www.neochart.com/catalog/cases/us/volume_526/0040_01/index.html
Like the state-action requirement of the Fourteenth Amendment, the under-color-of-state-law element of §1983 excludes from its reach “‘merely private conduct, no matter how discriminatory or wrongful,’ ”
Action taken by private entities with the mere approval or acquiescence of the State is not state action.
a private party’s mere use of the State’s dispute resolution machinery, without the “overt, significant assistance of state officials,” Tulsa, supra, at 486, cannot.
We conclude that an insurer’s decision to withhold payment and seek utilization review of the reasonableness and necessity of particular medical treatment is not fairly attributable to the State.
All agree that the public officials responsible for administering the workers’ compensation system and the director of SWIF are state actors.
The first inquiry in every due process challenge is whether the plaintiff has been deprived of a protected interest in “property” or “liberty.”
Thus, for an employee’s property interest in the payment of medical benefits to attach under state law, the employee must clear two hurdles: First, he must prove that an employer is liable for a work-related injury, and second, he must establish that the particular medical treatment at issue is reasonable and necessary.
Consequently, they do not have a property interest — under the logic of their own argument — in having their providers paid for treatment that has yet to be found reasonable and necessary.
casedsl 1 case /us/526/0040-01 name American Manufacturers Mutual Insurance v. Sullivan cite 526 U.S. 40 (1999) court Supreme Court of the United States date 1999-03-03 url catalog/cases/us/volume_526/0040_01/index.html source ir/caselaw/us_526.jsonl sha1=894dd9465113ac664b93ed5544b72b910218b16d chars=44337 law 42usc1983 role applied posture civil class action for declaratory/injunctive relief and damages; private insurers dismissed (no state action), state officials dismissed on merits; CA3 reversed on both; certiorari on insurers' petition result claimant-lost element color-of-law : not-satisfied [law] variant private-party/private-insurer-using-state-authorized-withholding-procedure party private workers' compensation insurers and self-insured employers fact @5871..6138 [cuts-against] | Named as defendants were various Pennsylvania officials who administer the Act, the director of the SWIF, the School District of Philadelphia (which self-insures), and a number of private insurance companies who provide workers’ compensation coverage in Pennsylvania. fact @3433..3572 [supports] | Upon the proper filing of a request, an insurer may withhold payment to health care providers for the particular services being challenged. fact @14382..14480 [cuts-against] | It authorizes, but does not require, insurers to withhold payments for disputed medical treatment. fact @18931..19215 [cuts-against] | the Bureau’s participation is limited to requiring insurers to file “a form prescribed by the Bureau,” 84 Pa. Code § 127.452, processing the request for technical compliance, and then forwarding the matter to a URO and informing the parties that utilization review has been requested. fact @20896..21064 [cuts-against absent] | nothing in Pennsylvania’s Constitution or statutory scheme obligates the State to provide either medical treatment or workers’ compensation benefits to injured workers. rule @9774..9977 | Like the state-action requirement of the Fourteenth Amendment, the under-color-of-state-law element of §1983 excludes from its reach “‘merely private conduct, no matter how discriminatory or wrongful,’ ” rule @13972..14077 | Action taken by private entities with the mere approval or acquiescence of the State is not state action. rule @18073..18238 | a private party’s mere use of the State’s dispute resolution machinery, without the “overt, significant assistance of state officials,” Tulsa, supra, at 486, cannot. held @25713..25908 | We conclude that an insurer’s decision to withhold payment and seek utilization review of the reasonableness and necessity of particular medical treatment is not fairly attributable to the State. gloss All three private-party routes rejected: nexus/coercion-encouragement (State merely permits the choice), public function (State has no obligation to provide benefits; withholding was historically a private prerogative), joint participation (heavy regulation is not Burton; no ex parte seizure by officials as in Lugar). First Lugar prong (acting pursuant to state statute) was met; second (state actor) failed. element color-of-law : satisfied [conceded] variant public-official/administering-statutory-scheme party state officials administering the Act and the director of the State Workmen's Insurance Fund held @12211..12352 | All agree that the public officials responsible for administering the workers’ compensation system and the director of SWIF are state actors. element deprivation.procedural-due-process : not-satisfied [law] variant property-interest/benefit-entitlement-not-yet-established fact @6139..6395 [supports] | Respondents alleged that in withholding workers’ compensation benefits without predeprivation notice and an opportunity to be heard, the state and private defendants, acting “under color of state law,” deprived them of property in violation of due process. fact @30615..30822 [cuts-against absent] | While they indeed have established their initial eligibility for medical treatment, they have yet to make good on their claim that the particular medical treatment they received was reasonable and necessary. rule @27361..27504 | The first inquiry in every due process challenge is whether the plaintiff has been deprived of a protected interest in “property” or “liberty.” rule @30072..30393 | Thus, for an employee’s property interest in the payment of medical benefits to attach under state law, the employee must clear two hurdles: First, he must prove that an employer is liable for a work-related injury, and second, he must establish that the particular medical treatment at issue is reasonable and necessary. held @30823..31011 | Consequently, they do not have a property interest — under the logic of their own argument — in having their providers paid for treatment that has yet to be found reasonable and necessary. gloss State law conditions the entitlement on reasonableness/necessity, so withholding pending review deprives of nothing; property interest in the claim itself (Logan) expressly not addressed. element person : not-reached element causation : not-reached element policy : not-reached gloss School District of Philadelphia (self-insurer, municipal corporation) was a defendant, but its state-actor status and any Monell question were never decided. element damages : not-reached misfit The court states the 1983 claim as two elements only (deprivation + color of law) and notes that for Fourteenth Amendment claims color-of-law and constitutional "state action" converge (now law-file constraint state-action-convergence); the case notation still has one slot (color-of-law) for what is simultaneously a statutory element and part of the constitutional deprivation. misfit State action is itself a two-prong test (Lugar): (1) deprivation caused by exercise of a state-created right/rule -- satisfied; (2) defendant fairly a state actor -- failed. The law file now declares color-of-law.state-created-right / .state-actor, but this file keeps one not-satisfied `color-of-law` block: the satisfied first prong has no quote (quote set frozen at migration) and the law file itself catalogues this case under the parent id. misfit One not-satisfied color-of-law block rejects three alternative tests (nexus/encouragement, public function, joint participation); a single variant label cannot carry "all routes tried and failed" -- would need multiple variants per block or one block per theory. misfit Facts here are legislative facts (how the statutory scheme works), not who-did-what; a facial challenge to a statute has almost no adjudicative facts to put on `fact` lines. misfit Part III (no property interest) is an alternative holding as to the private insurers (already out under Part II) but the ONLY ground reaching the concededly-state-actor defendants, whose own certiorari petitions were denied. `scope alternative` is per block, not per party, so the block is left at merits; the notation cannot say a holding is alternative for some parties and primary for others, or which defendants it formally binds. misfit Fractured court: Part II (state action) and Part III (property) command different majorities; Ginsburg declines Part II, Stevens dissents in part (would affirm as to original procedure), Breyer reserves reliance-based property interests. No way to record vote alignment per element.