Manda Roberson v. The Dakota Boys & Girls Ranch, 42 F.4th 924

Background

In May 2018 a North Dakota juvenile court removed 12‑year‑old A.A.R. from her parents and placed her under the full care, custody, and control of the State (Division of Juvenile Services, DJS) for one year.
DJS initially placed A.A.R. at the Youth Correctional Center; after a suicide attempt in August 2018 DJS transferred her to the Dakota Boys & Girls Ranch, a private psychiatric residential treatment facility (PRTF), for an anticipated four‑month medical placement.
The Ranch developed and implemented a full treatment plan (medication, therapy, schooling, housing); staff placed A.A.R. on line‑of‑sight restrictions and documented suicidal ideation.
On October 2, 2018, A.A.R. concealed a bedsheet, was permitted to enter the bathroom while staff were immediately outside, and died by suicide there; her parents sued the Ranch and two staffers under 42 U.S.C. § 1983 alleging deliberate indifference and related claims.
The district court dismissed for failure to plead the Ranch was a state actor; the Eighth Circuit reversed, holding the complaint plausibly alleged the Ranch (and its employees) acted under color of state law because North Dakota outsourced its constitutional duty to provide medical care for a state ward to the Ranch.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the private Ranch and its employees acted under color of state law for § 1983 purposes	DJS had custody and placed A.A.R. at the Ranch; the Ranch assumed the State’s constitutional duty to provide medical/psychiatric care, so it is a state actor	Ranch was a private provider, had no contract, and PRTF admission is not incarceration; at most the State approved/acquiesced	Reversed: complaint plausibly alleges state action—the Ranch performed a traditional, exclusive public function by providing care to a state ward, so it and its employees may be § 1983 defendants
Whether the State had a constitutional duty to provide psychiatric/medical care to A.A.R. while in its custody	When the State restrains a person’s liberty and the person cannot care for themselves, the Fourteenth Amendment/Due Process requires the State to provide medical and safety services	(Defendants did not meaningfully contest that custody created a state duty)	Held that DJS’s custody created a constitutional duty to provide medical/psychiatric care to A.A.R.
Whether the absence of a formal contract or payment relationship defeats state‑actor status	Contract/ payment not required; the dispositive inquiry is whether the private actor performed the State’s function and had the State’s authorization to treat a person who had no choice	Lack of contractual nexus indicates private action, not state action; mere compliance with PRTF rules is insufficient	Court held that lack of contract does not preclude state action where the private provider assumed the State’s role (West/Conner/Rodriguez framework)
Whether Ranch employees (Holweger and James) are state actors if the Ranch is	If the Ranch is a state actor, its employees acting in providing the State‑assumed care are state actors too	Employees are private staff of a private facility, not state actors	Court held employees plausibly state actors because they acted as agents of a private provider that assumed the State’s custodial medical responsibilities

Key Cases Cited

West v. Atkins, 487 U.S. 42 (1988) (private physician treating prisoners is a state actor when the State has outsourced its duty to provide inmate medical care)
DeShaney v. Winnebago Cnty. Dep’t of Soc. Servs., 489 U.S. 189 (1989) (State has due‑process duty to provide for basic needs, including medical care, when it restrains liberty and renders a person unable to care for themselves)
Manhattan Cmty. Access Corp. v. Halleck, 139 S. Ct. 1921 (2019) (framework and limits for when private entities may be characterized as state actors)
Norfleet ex rel. Norfleet v. Arkansas Dep’t of Hum. Servs., 989 F.2d 289 (8th Cir. 1993) (State’s obligation to provide adequate medical care, protection, and supervision to children when it assumes custody)
Conner v. Donnelly, 42 F.3d 220 (4th Cir. 1994) (a physician treating a prisoner without a formal contract can still be a state actor under West)
Rodriguez v. Plymouth Ambulance Serv., 577 F.3d 816 (7th Cir. 2009) (a private hospital treating a prisoner for an extended stay assumed the State’s responsibility and could be a state actor)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: complaint must allege sufficient factual matter to state a plausible claim)