United States v. Universal Health Services, Inc., 3:16-cv-00001

Four plaintiffs (Settles, Byrd, Sharp, Hembrock) sued River Point and related private entities/employees after involuntary confinement under Florida’s Baker Act, alleging state-law torts and a federal § 1983 claim for deprivation of liberty.
Defendants removed three suits from state court to federal court; Settles’ case proceeded in federal court after the United States and relator dismissed the False Claims Act count.
Defendants are alleged to be private entities (UHS and subsidiaries, Baptist in one case) and individual clinicians; plaintiffs alleged defendants acted “under color of state law” via the Baker Act to justify § 1983 claims.
The court applied Twombly/Iqbal pleading standards and assessed whether private defendants’ conduct was fairly attributable to the state (Lugar) to support § 1983 liability.
The court concluded plaintiffs failed to allege facts showing state action; § 1983 claims were dismissed with prejudice. Because no federal claims remained, the court declined supplemental jurisdiction in Settles (state claims dismissed without prejudice) and remanded the three removed cases (Byrd, Sharp, Hembrock) to state court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants were state actors under § 1983	Defendants acted under color of state law by enforcing the Baker Act	Defendants are private actors; acting under a statute does not automatically make them state actors	Plaintiffs failed to plead facts showing state action; § 1983 claims dismissed with prejudice
Whether § 1983 claims met federal pleading standards	Section 1983 claims sufficient because involuntary commitment implicates liberty interests	Claims are conclusory and lack factual allegations tying defendants to state action	Claims did not meet Twombly/Iqbal; dismissal warranted
Whether the court should exercise supplemental jurisdiction in Settles	Implicit: keep related state claims in federal court	Move to dismiss § 1983; argue state-law claims better resolved in state court after dismissal of federal claim	Court declined supplemental jurisdiction; Settles’ state claims dismissed without prejudice
Whether remand of removed cases is appropriate (Byrd, Sharp, Hembrock)	Plaintiffs favored state forum; rely on state-law claims after § 1983 dismissal	Defendants removed on federal-question grounds; urged retention?	Court remanded the three removed cases to state court and carried remaining dismissal motions with the remand

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard: plausibility required for nonconclusory factual allegations)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (requires factual allegations to raise claim above speculative level)
Lugar v. Edmondson Oil Co., 457 U.S. 922 (state action requires conduct to be fairly attributable to the state)
Foshee v. Health Mgmt. Associates, 675 So. 2d 957 (Fla. Dist. Ct. App.) (private psychiatric facility acting under commitment statute was not a state actor for § 1983)
Harvey v. Harvey, 949 F.2d 1127 (11th Cir.) (private hospital/physicians acting under commitment statute were not state actors)
Carnegie–Mellon Univ. v. Cohill, 484 U.S. 343 (when federal claims drop out early, courts should generally decline supplemental jurisdiction in favor of state adjudication)