Gonzalez-Trapaga v. Mayaguez Med. Ctr. Dr. Ramon Emeterio Betances, Inc. — Mar. 2016 (Summary)

DISCRIMINATION

Gonzalez-Trapaga v. Mayaguez Med. Ctr. Dr. Ramon Emeterio Betances, Inc.
Civil No. 15-1342 (DRD) (D.P.R. Mar. 30, 2016)

The United States District Court of Puerto Rico granted in part and denied in part motions to dismiss brought by a municipality, a medical center and physicians regarding a physician’s claims under §1983 and the Social Security Act. The physician alleged the defendants violated his due process rights under the Fourteenth Amendment and retaliated against him in violation of the Social Security Act for his bringing to the attention of others the medical center’s failure to implement an on-call duty system, which disproportionately harmed solo practitioners like the physician. With regard to the physician’s §1983 claim, the district court found the municipality did not take direct action because the fact that the municipality leased the hospital facilities to the medical center did not make the municipality responsible for the conduct of private parties. The municipality had no way to force the medical center to take action, and was not involved in a profit-sharing arrangement with the medical center.

With regard to indirect state action, the district court found that the medical center’s conduct of providing health services was not a “public function” that was traditionally the responsibility of the state. Additionally, the court found the municipality in no way attempted to coerce the medical center into taking a certain course of action. Finally, the district court held that, reviewing the totality of the circumstances, the municipality was not “so far insinuated” in a position with the medical center that the municipality became a joint participant in the medical center’s activities. The district court found the municipality had no authority to control or influence the day-to-day affairs of the medical center, which was found to be “the most salient factor.” Additionally, the district court did not find the municipality profited in any way from the medical center’s failure to adopt an on-call duty program.

The district court also dismissed the physician’s private causes of action under the Social Security Act, holding the physician’s alleged causes of action pertained to a different section of the statute that did not reference the requirement to establish an on-call duty program or whistleblower protections.