American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999

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; claim:

Uncertainty

opinion: Parts I-II and Part III command different majorities (reporter's syllabus, not in the IR: I-II = Rehnquist, O'Connor, Scalia, Kennedy, Souter, Thomas, Breyer; III = Rehnquist, O'Connor, Kennedy, Thomas, Ginsburg, with Breyer and Souter "insofar as"), so the opinion of the Court is declared as two controlling opinions. The IR text itself confirms only Scalia (I-II), Ginsburg (III, not II) and Breyer+Souter.

opinion: the 13 footnotes are appended after "Reversed." with their numbers stripped; the split nn. 1-11 -> court12 (@31590..36741) and nn. 12-13 -> court3 (@36741..37648) is by content, not by a marker in the text.

opinion: Stevens writes "concurring in part and dissenting in part"; declared `dissent` (no mixed kind). No block is `by` gins / brey / stev: the frozen quote set has no quote inside their spans.

Element color-of-law: polarity: @5871..6138 only lists who was sued (officials, SWIF, school district, private insurers); v1 forced [cuts-against] onto it, now [neutral].

Element color-of-law: opinion: @6139..6395 (the due process claim as pleaded, in Part I) was a [supports] fact of the deprivation block in v1. That block is `by court3` and Part I belongs to court12, so the quote had to move here, where it is only context ([neutral]: it alleges that all defendants acted "under color of state law"). The deprivation block thereby loses its statement of the claim.

Element color-of-law: variant: one variant label for three rejected routes (the three `theory` ids); no quote is specific to joint-participation.

Element deprivation.procedural-due-process: scope: Part III is an alternative ground for the insurers (already out under Part II) and the only ground for the officials; scope is per block and the quotes cannot be duplicated into a second block, so the block stays `merits` for both parties.

Element deprivation.procedural-due-process: other: whether the holding formally binds the officials is unclear from the text: their own certiorari petitions were denied, yet the Court reverses the judgment as a whole and says Part III has "ramifications" for them.

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 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) and the law file itself catalogues this case under the parent id.

The three state-actor tests are alternative ROUTES to one element (any one suffices for the plaintiff; all must fail for the defendant). v1.1 names them as three `theory` ids on one block, but a block still has one variant and one holding, and the law file has no construct for any-of routes to cite (`mode` = the court selects one; `protocol` = stages in sequence).

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, and v1.1 polarity has no way to mark a fact as legislative.

Per-party scope: Part III is `alternative` for the insurers and the sole ground for the concededly-state-actor officials. Party ids now name both, but `scope` is still one value per block; splitting the block would leave one half without quotes.

Vote alignment: the per-Part opinions say which text had which majority, but an `opinion` line has an author only -- who JOINED (7 for Parts I-II, 5 for Part III, two "insofar as") and that Ginsburg's concurrence supplies the fifth vote for Part III have no field. The three separate writings are declared as spans but carry no blocks (Ginsburg / Stevens: the claim itself is property and the original procedure was deficient; Breyer: reliance-based property reserved).

A block is `by` exactly one opinion and spans may not overlap, so a block cannot quote Part I (statement of the case, joined with Part II) together with Part III; with per-Part opinions the background facts of the case are only quotable by Part II blocks.

interpretation

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,’ ”

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

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,’ ”

Under West v. Atkins (487 U.S. 42 (1988)), traditional definition requires that the defendant exercised power "possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law". Note Polk County v. Dodson (454 U.S. 312 (1981)) later reversed the Eighth Circuit's Dodson holding on public defenders, holding a public defender does not act under color of state law when performing a lawyer's traditional functions as counsel to a defendant in a criminal proceeding.

interpretation

Action taken by private entities with the mere approval or acquiescence of the State is not state action.

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

Action taken by private entities with the mere approval or acquiescence of the State is not state action.

Under West v. Atkins (487 U.S. 42 (1988)), traditional definition requires that the defendant exercised power "possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law". Note Polk County v. Dodson (454 U.S. 312 (1981)) later reversed the Eighth Circuit's Dodson holding on public defenders, holding a public defender does not act under color of state law when performing a lawyer's traditional functions as counsel to a defendant in a criminal proceeding.

interpretation

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.

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

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.

Under West v. Atkins (487 U.S. 42 (1988)), traditional definition requires that the defendant exercised power "possessed by virtue of state law and made possible only because the wrongdoer is clothed with the authority of state law". Note Polk County v. Dodson (454 U.S. 312 (1981)) later reversed the Eighth Circuit's Dodson holding on public defenders, holding a public defender does not act under color of state law when performing a lawyer's traditional functions as counsel to a defendant in a criminal proceeding.

interpretation

Action taken by private entities with the mere approval or acquiescence of the State is not state action.

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

Action taken by private entities with the mere approval or acquiescence of the State is not state action.

Second prong of Lugar: whether the private or hybrid entity may fairly be treated as a state actor under the public-function test, state-compulsion/nexus test, symbiotic-relationship test, or joint-action test.

interpretation

The first inquiry in every due process challenge is whether the plaintiff has been deprived of a protected interest in “property” or “liberty.”

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

The first inquiry in every due process challenge is whether the plaintiff has been deprived of a protected interest in “property” or “liberty.”

Two-step inquiry: (1) whether plaintiff was deprived of a protected liberty or property interest (see `.due-process-property` and `.due-process-liberty`), and (2) whether the procedures attendant upon that deprivation were constitutionally sufficient (Mathews v. Eldridge).

interpretation

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.

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

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.

Two-step inquiry: (1) whether plaintiff was deprived of a protected liberty or property interest (see `.due-process-property` and `.due-process-liberty`), and (2) whether the procedures attendant upon that deprivation were constitutionally sufficient (Mathews v. Eldridge).

interpretation

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,’ ”

American Manufacturers Mutual Insurance v. Sullivan — 526 U.S. 40 (1999) · Supreme Court of the United States · 1999 (42usc1983: author: Fable · historical QA: PASS (QA1, neov2/qa/cases-v1-QA1.md) · changed after review; current content not independently reviewed)

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,’ ”

In Fourteenth Amendment claims, the statutory "under color of" state law requirement and the constitutional "state action" requirement converge.