Supreme Court of the United States · 1999-03-03
Case and law context
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:
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Variant | Exact source quotations |
|---|---|---|---|---|
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Personal involvement / causal connection ("subjects, or causes to be subjected") | not_reached Excluded from merits counts applied / merits | Unspecified variant | No source quotation recorded for this block. |
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Action taken "under color of" state, territorial, or D.C. law | not Counted merits instance applied / merits basis: law; party: private workers' compensation insurers and self-insured employers (petitioners); theory: state coercion or significant encouragement (Blum / Jackson close-nexus test); delegation of a traditionally exclusive public function; joint participation / symbiotic entanglement (Burton; Lugar); subject: party=private workers' compensation insurers and self-insured employers (petitioners); theory=state coercion or significant encouragement (Blum / Jackson close-nexus test); delegation of a traditionally exclusive public function; joint participation / symbiotic entanglement (Burton; Lugar) 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. | private-party/private-insurer-using-state-authorized-withholding-procedure | Upon the proper filing of a request, an insurer may withhold payment to health care providers for the particular services being challenged.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [3433:3572] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.It authorizes, but does not require, insurers to withhold payments for disputed medical treatment.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [14382:14480] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [18931:19215] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.nothing in Pennsylvania’s Constitution or statutory scheme obligates the State to provide either medical treatment or workers’ compensation benefits to injured workers.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [20896:21064] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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,’ ”Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [9774:9977] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.Action taken by private entities with the mere approval or acquiescence of the State is not state action.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [13972:14077] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [18073:18238] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [25713:25908] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97. |
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Action taken "under color of" state, territorial, or D.C. law | satisfied Counted merits instance applied / merits basis: conceded; party: state officials administering the Act and the director of the State Workmen's Insurance Fund (own certiorari petitions denied); subject: party=state officials administering the Act and the director of the State Workmen's Insurance Fund (own certiorari petitions denied) | public-official/administering-statutory-scheme | All agree that the public officials responsible for administering the workers’ compensation system and the director of SWIF are state actors.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [12211:12352] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97. |
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Damages remedy (legacy CASE id; not a prerequisite for prospective relief) | not_reached Excluded from merits counts applied / merits | Unspecified variant | No source quotation recorded for this block. |
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Deprivation of Fourteenth Amendment Procedural Due Process (protected liberty/property interest + inadequate process) | not Counted merits instance applied / merits basis: law; party: private workers' compensation insurers and self-insured employers (petitioners); state officials administering the Act and the director of the State Workmen's Insurance Fund (own certiorari petitions denied); theory: property interest in payment of medical bills before reasonableness and necessity are determined; opinion: majority (Rehnquist); subject: party=private workers' compensation insurers and self-insured employers (petitioners); state officials administering the Act and the director of the State Workmen's Insurance Fund (own certiorari petitions denied); theory=property interest in payment of medical bills before reasonableness and necessity are determined; opinion=majority (Rehnquist) 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. | property-interest/benefit-entitlement-not-yet-established | 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.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [30615:30822] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.The first inquiry in every due process challenge is whether the plaintiff has been deprived of a protected interest in “property” or “liberty.”Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [27361:27504] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [30072:30393] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.Source: docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [30823:31011] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97. |
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Suable "person" (natural person in individual capacity, official in official capacity for prospective relief, or municipality; excludes States) | not_reached Excluded from merits counts applied / merits | Unspecified variant | No source quotation recorded for this block. |
| /us/526/0040-01 — Supreme Court of the United States · 1999 | Municipal policy or custom as moving force (Monell v. Department of Social Services) | not_reached Excluded from merits counts applied / merits party: School District of Philadelphia, self-insurer and municipal corporation (own certiorari petition denied); subject: party=School District of Philadelphia, self-insurer and municipal corporation (own certiorari petition denied) School District of Philadelphia (self-insurer, municipal corporation) was a defendant, but its state-actor status and any Monell question were never decided. | Unspecified variant | No source quotation recorded for this block. |
Court interpretations recorded from this case
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,’ ”
/us/526/0040-01 — Supreme Court of the United States · 1999
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,’ ”Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [9774:9977] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.
/us/526/0040-01 — Supreme Court of the United States · 1999
Action taken by private entities with the mere approval or acquiescence of the State is not state action.Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [13972:14077] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.
/us/526/0040-01 — Supreme Court of the United States · 1999
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.Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [18073:18238] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.
/us/526/0040-01 — Supreme Court of the United States · 1999
Action taken by private entities with the mere approval or acquiescence of the State is not state action.Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [13972:14077] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.”
/us/526/0040-01 — Supreme Court of the United States · 1999
The first inquiry in every due process challenge is whether the plaintiff has been deprived of a protected interest in “property” or “liberty.”Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [27361:27504] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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.
/us/526/0040-01 — Supreme Court of the United States · 1999
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.Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [30072:30393] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.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,’ ”
/us/526/0040-01 — Supreme Court of the United States · 1999
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,’ ”Source:
docroot/ir/caselaw/us_526.jsonl#/us/526/0040-01; Unicode character offsets [9774:9977] (end exclusive); SHA-256 2f09bb34600ef67ab16a649c9f0dbc25827219d340838e2c2ae98add5e866c97.In Fourteenth Amendment claims, the statutory "under color of" state law requirement and the constitutional "state action" requirement converge.