## Facts

- Quincy West, a North Carolina state prisoner, injured his leg (a torn Achilles tendon) while incarcerated.
- North Carolina required inmates to obtain medical care through the prison system and barred West from selecting a physician of his own choosing.
- Dr. Samuel Atkins, a private orthopedic physician, contracted with the State to provide part-time services at a state-prison hospital.
- West alleged Atkins provided constitutionally inadequate medical care amounting to deliberate indifference to serious medical needs in violation of the Eighth Amendment.
- West filed a 42 U.S.C. § 1983 action against Atkins.

## Issues

1. Whether a private physician under contract with a State to provide part-time medical services at a state-prison hospital acts “under color of state law” under 42 U.S.C. § 1983 when treating an inmate.
2. Whether the lower courts erred by granting summary judgment on the ground that the contract physician was not a state actor.

## Decision

- The Supreme Court held that a physician under contract with the State to provide medical services to inmates acts under color of state law when treating an inmate.
- The Court reversed the Fourth Circuit’s judgment and remanded for further proceedings.
- The Court rejected the view that exercising professional medical judgment, without custodial or supervisory authority, removes a prison medical professional from § 1983 coverage.
- The Court distinguished public defenders performing an adversarial function from prison physicians performing the State’s duty to provide inmate medical care.

## Legal Principles

- Conduct satisfies § 1983’s “under color of state law” requirement when it is fairly attributable to the State (aligned with Fourteenth Amendment state-action analysis).
- A State has an Eighth Amendment obligation to provide adequate medical care to incarcerated persons; when the State delegates that duty to a physician, the physician’s treatment of inmates is attributable to the State.
- The relevant inquiry is the provider’s function within the State’s correctional medical system, not the technical terms of employment (e.g., contract status, payroll status, or nonexclusive work).
- Because inmates are compelled to rely on the prison medical system and cannot obtain outside care, medical services provided through that system carry the State’s authority for state-action purposes.

## Conclusion

A contract physician providing prison medical care performs a function the State is constitutionally required to supply, so the physician acts under color of state law when treating inmates; dismissal of West’s § 1983 claim on the sole ground that the physician was a private contractor was improper, requiring reversal and remand.


West v. Atkins, 487 U.S. 42 (1988)