## Facts

- New York City decided to close Sydenham Hospital, a municipal hospital in central Harlem serving a patient population described as approximately 98% Black and Hispanic.
- The decision occurred during a severe municipal fiscal crisis and was presented as part of a cost-reduction and efficiency plan for the City’s hospital system.
- The City cited Sydenham’s high operating deficits, outdated facilities, and the availability of comparable services at other municipal hospitals within roughly a 30-minute travel radius.
- Plaintiffs included individual residents and patients, municipal employees and their union, and community organizations; they alleged the closure would disproportionately burden minority and low-income residents by reducing access to hospital care.
- Plaintiffs sought to enjoin the closure primarily under Title VI of the Civil Rights Act of 1964, asserting unlawful discrimination connected to the use of federal funds.
- The district court denied a preliminary injunction, finding plaintiffs unlikely to succeed on the merits and failing to show irreparable harm sufficient for preliminary relief.
- Plaintiffs appealed the denial of preliminary injunctive relief to the Second Circuit.

## Issues

1. Whether plaintiffs showed a likelihood of success that the hospital closure violated Title VI by constituting unlawful racial discrimination.
2. Whether plaintiffs satisfied the requirements for a preliminary injunction, including irreparable harm absent an injunction.

## Decision

- The Second Circuit affirmed the denial of a preliminary injunction.
- The court held plaintiffs had not shown a likelihood of success on their Title VI claim because the record did not support an inference that the closure decision was motivated by discriminatory purpose.
- The court concluded plaintiffs did not establish irreparable harm warranting preliminary relief, given the City’s plans for alternative care and nearby facilities.
- The court declined, at the preliminary injunction stage, to treat Title VI as requiring selection of the least discriminatory alternative among cost-saving options absent proof of discriminatory intent.

## Legal Principles

- A Title VI claim challenging governmental reconfiguration or closure of public services generally requires proof of discriminatory intent, not disparate impact alone.
- Evidence of disproportionate effects on a minority population may be relevant but is insufficient, without more, to establish unlawful discrimination for preliminary injunctive relief.
- In assessing preliminary injunction requests, courts weigh likelihood of success on the merits and irreparable harm; failure to show either can justify denial.
- Fiscal and operational reasons—such as budget constraints, facility condition, system efficiency, and availability of alternative services—can constitute legitimate, non-pretextual justifications absent proof they mask discriminatory purpose.

## Conclusion

The Second Circuit affirmed denial of preliminary injunctive relief against closure of a Harlem municipal hospital, holding that plaintiffs had not shown likely success under Title VI without evidence of discriminatory intent and had not demonstrated irreparable harm sufficient to justify an injunction in light of the City’s mitigation plans and alternative access to care.


Bryan v. Koch, 627 F.2d 612 (2d Cir. 1980)