Timothy Carl v. Muskegon County
763 F.3d 592
| 6th Cir. | 2014Background
- Timothy Carl, a pretrial detainee with a history of mental illness, was evaluated at Muskegon County Jail after alarming behavior.
- CMH, contracted by the county, provided mental health services to jail inmates under an operating agreement.
- Dr. Katherine Jawor, an independent contractor, examined Carl on March 5 and concluded he did not meet criteria for involuntary hospitalization.
- The district court granted summary judgment in favor of Dr. Jawor, holding she was not acting under color of state law.
- Carl alleged a violation of his Eighth/Fourteenth Amendment rights due to denial of necessary mental health treatment while in custody, with other defendants settling and only Jawor remaining at issue on appeal.
- Appellate review affirmed reversal of the district court, remanding for further proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jawor acted under color of state law | Carl: Jawor performed a state-function evaluation in custody. | Jawor: private psychiatrist; not a state actor. | Yes; Jawor acted under color of state law. |
| Whether private contractors can be state actors under the public-function test | Carl relies on private contract to show state control over essential functions. | Jawor: contract alone not determinative; must show public function and state control. | Yes; private medical evaluators can be state actors when performing a traditionally state-function. |
| Whether contracting with CMH makes Jawor a state actor | Carl: CMH contract to provide inmate care vests state-actor status in Jawor. | Jawor: status determined by function, not mere employment terms. | Yes; contract and function together support state-actor status. |
| Whether the district court erred in granting summary judgment | Carl: district court misapplied state-actor analysis and ignored established law on outsourcing. | Jawor: no state action under district court's framework. | Corrected; district court erred; summary judgment reversed. |
| Whether Ellison or Wolotsky governs here | Carl: earlier Sixth Circuit cases support state-actor status. | Jawor: those decisions are distinguishable; this is custodial context. | Distinguishable; West-based analysis controls; state action present. |
Key Cases Cited
- West v. Atkins, 487 U.S. 42 (1988) (private doctor under contract can be state actor when performing state functions)
- Estelle v. Gamble, 429 U.S. 97 (1976) (government obligation to provide medical care to those in custody)
- Johnson v. Karnes, 398 F.3d 868 (6th Cir. 2005) (private physicians serving inmate populations may be sued under § 1983)
- Street v. Corr. Corp. of Am., 102 F.3d 810 (6th Cir. 1996) (private entity providing prison medical care may be state actor)
- Hicks v. Frey, 992 F.2d 1450 (6th Cir. 1993) (private provider can act under color of state law when contracted to provide care)
- Ellison v. Garbarino, 48 F.3d 192 (6th Cir. 1995) (distinguishable; involuntary commitment context differs; employment not dispositive)
- Wolotsky v. Huhn, 960 F.2d 1331 (6th Cir. 1992) (context matters; custodial setting distinguishes from non-custodial mental health services)
- Conner v. Donnelly, 42 F.3d 220 (4th Cir. 1994) (private doctor treated inmate; state-actor status permissible)
- United States v. Classic, 313 U.S. 299 (1941) (determinative framework for state action and private conduct attribution)
- Lugar v. Edmondson Oil Co., 457 U.S. 922 (1982) (test for state action based on state involvement)
- Chapman v. Higbee Co., 319 F.3d 825 (6th Cir. 2003) (public-function test interpreted narrowly in private actions)