## Facts

- William Allen Spencer, who had a history of serious mental illness, was involuntarily committed to St. Elizabeth Hospital, a private hospital, in 1982 and again in 1984 on the authorization of Dr. Bumyong Lee, a private physician.
- During the second commitment, police transported Spencer to the hospital against his will.
- Spencer was hospitalized for about five days; on the fourth day Dr. Lee ordered an injection of medication that Spencer claimed caused injury after he warned he was allergic.
- Spencer sued Dr. Lee and St. Elizabeth under 42 U.S.C. § 1983, alleging (1) deprivation of liberty without due process through involuntary confinement and (2) reckless infliction of injury via medication.
- Spencer also asserted Illinois state-law claims for false imprisonment and medical malpractice.
- Spencer argued the Illinois involuntary commitment scheme effectively made private physicians and hospitals state actors by delegating a governmental function.

## Issues

1. Whether a private physician and private hospital act “under color of state law” for 42 U.S.C. § 1983 purposes by involuntarily committing an individual under Illinois’s mental health commitment procedures.
2. If there is no state action, whether dismissal of the federal claim requires dismissal of pendent state-law claims.

## Decision

- The Seventh Circuit (en banc) affirmed dismissal for failure to state a claim.
- The court held Dr. Lee and St. Elizabeth were not acting under color of state law merely by using Illinois’s commitment procedures.
- With the § 1983 claim dismissed, the pendent Illinois false imprisonment and malpractice claims were dismissed without a federal basis for jurisdiction.

## Legal Principles

- § 1983 liability requires conduct fairly attributable to the state; the Fourteenth Amendment due process clause targets governmental, not purely private, action.
- State regulation, licensing, or statutory authorization of private conduct—standing alone—does not convert private parties into state actors.
- Private physicians and private hospitals do not become state actors simply because state law permits or structures involuntary civil commitment; additional ties to the state (e.g., public employment, contract, or joint participation) are required.
- Federal civil-rights law does not federalize ordinary private tort allegations (such as false imprisonment or malpractice) absent state action.

## Conclusion

The court concluded that a purely private physician and hospital are not state actors for § 1983 purposes when they commit a person under state involuntary commitment procedures, so alleged wrongful confinement and treatment present state tort claims rather than federal constitutional claims.


Spencer v. Lee, 864 F.2d 1376 (7th Cir. 1989)