American Manufacturers Mutual Insurance v. Sullivan

526 U.S. 40 (1999) Supreme Court of the United States 1999-03-03

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)

Facts

  1. 2 Action taken "under color of" state, territorial, or D.C. law not law
    Upon the proper filing of a request, an insurer may withhold payment to health care providers for the particular services being challenged.
  2. 2 Action taken "under color of" state, territorial, or D.C. law not law
    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,’ ”
  3. 2 Action taken "under color of" state, territorial, or D.C. law satisfied conceded
    All agree that the public officials responsible for administering the workers’ compensation system and the director of SWIF are state actors.
  4. 2 Action taken "under color of" state, territorial, or D.C. law not law
    Action taken by private entities with the mere approval or acquiescence of the State is not state action.
  5. 2 Action taken "under color of" state, territorial, or D.C. law not law
    It authorizes, but does not require, insurers to withhold payments for disputed medical treatment.
  6. 2 Action taken "under color of" state, territorial, or D.C. law not law
    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.
  7. 2 Action taken "under color of" state, territorial, or D.C. law not law
    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.
  8. 2 Action taken "under color of" state, territorial, or D.C. law not law
    nothing in Pennsylvania’s Constitution or statutory scheme obligates the State to provide either medical treatment or workers’ compensation benefits to injured workers.
  9. 2 Action taken "under color of" state, territorial, or D.C. law not law
    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.