Rawson v. Recovery Innovations, Inc., No. 19-35520 (9th Cir. 2020)
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The Ninth Circuit reversed the district court's summary judgment dismissal of plaintiff's 42 U.S.C. 1983 claims against RII and its current and former employees, alleging that defendants violated his Fourth and Fourteenth Amendment rights by wrongfully detaining him, forcibly injecting him with antipsychotic medications, and misleading a court into extending his period of involuntary commitment for a total of 55 days.
The panel held that defendants were acting under color of state law with respect to the actions for which plaintiff attempts to hold them liable. The panel stated that, given the necessity of state imprimatur to continue detention, the affirmative statutory command to render involuntary treatment, the reliance on the State's police and parens patriae powers, the applicable constitutional duties, the extensive involvement of the county prosecutor, and the leasing of their premises from the state hospital, a sufficiently close nexus between the state and the private actor existed here so that the action of the latter may be fairly treated as that of the State itself.
Court Description: Civil Rights. The panel reversed the district court’s summary judgment in favor of defendants and remanded in an action brought pursuant to 42 U.S.C. § 1983 alleging that defendants, a private nonprofit corporation and three of its current and former employees, violated plaintiff’s Fourth and Fourteenth Amendment rights by wrongfully detaining him, forcibly injecting him with antipsychotic medications, and misleading a court into extending his period of involuntary commitment for a total of 55 days. The district court dismissed plaintiff’s claims against defendants based on the conclusion that defendants were not acting under color of state law. The panel held that, although defendants were nominally private actors, exercised professional medical judgment, and were not statutorily required to petition for additional commitment, on balance, the facts weighed toward a conclusion that they were nevertheless state actors. The panel held that given the necessity of state imprimatur to continue detention, the affirmative statutory command to render involuntary treatment, the reliance on the State’s police and parens patriae powers, the applicable constitutional duties, the extensive involvement of the county prosecutor, and the leasing of defendants’ premises from the state hospital, “a sufficiently close nexus between the state and the private actor” existed here “so that the action of the latter may be RAWSON V. RECOVERY INNOVATIONS 3 fairly treated as that of the State itself.” Jensen v. Lane Cty., 222 F.3d 570, 575 (9th Cir. 2000). The panel therefore concluded that defendants were acting under color of state law with respect to the actions for which plaintiff attempted to hold them liable.
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