West v. Atkins

Supreme Court of the United States · 1988 · Federal Courts

Federal CourtsSection 1983State ActionPrison Medical Care42 U.S.C. § 1983under color of state lawstate actionprison doctor

Facts

While incarcerated in a North Carolina state prison, West tore his Achilles tendon and was referred to Central Prison Hospital for orthopedic treatment. Dr. Atkins, a private physician under contract with the State to provide part-time orthopedic services to inmates there, treated West over several months. West alleged Atkins acknowledged surgery was necessary but refused to schedule it and discharged him while his ankle remained swollen, painful, and impaired. Because West was a prisoner in close custody, he could not seek treatment from a different physician of his own choosing.

Issue

Whether a private physician who contracts with the State to provide medical services to inmates at a state-prison hospital on a part-time basis acts under color of state law, for purposes of § 1983, when treating an inmate.

Rule

For purposes of § 1983, a physician authorized and employed by the State to provide medical care to prison inmates acts under color of state law when undertaking that treatment. The dispositive inquiry is the physician's function within the state system and the relationship among the State, the physician, and the prisoner, not the precise terms of employment, the physician's professional status, or whether the physician works part time or by contract.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

The Ohio Department of Corrections contracts with Dr. Lena Morales, a private cardiologist in Columbus, to run one clinic each Friday inside a state prison infirmary. An inmate alleges Morales knowingly refused to treat a serious heart condition during one of those clinics and sues her under 42 U.S.C. § 1983.

Is Morales most likely acting under color of state law when treating the inmate?

Explanation. Yes. The majority held that a physician authorized and employed by the State to provide medical care to inmates acts under color of state law when undertaking that treatment. The key inquiry is the physician's function within the state system and the relationship among the State, physician, and prisoner—not part-time status, contract status, or the exercise of professional judgment.