The case is a good example of how federal laws came into play in the affairs of state action.
- At what level of the judicial court system did this legal opinion occur?
- What was the opinion of the lower court that was finally overturned in Simkins?
- Explain at least one the federal laws that was highlighted in Simkins v. Moses H. Cone .
- How did the federal law play a role in deciding this case?
- Identify and discuss the Constitutional amendments and issues in the case.
- Explain why the case was limited in its reach.
- Identify the federal official and agency that finally extended the cases’ ruling and how
the cases’ outcome spread across the Nation. - Read the blog “Basic Health Access”; Is the Institutes of Medicine Waking Up?
(February 22, 2013
Simkins v. Moses H. Cone Mem. Hospital makes or fails to make a big difference in
decreasing health inequities?
Assignment Expectations - Limit your responses to a maximum of five pages, not including title and reference list
pages. - Be sure to utilize at least 3-4 scholarly references to support your discussions.
- Be sure to properly cite your references within the text of your assignment and listed at
the end. - Be sure to apply critical thinking skills to the write-up of your assignment, especially
concerning #6 above.
Case Study
- The level of the judicial court system that this legal opinion occurred
This legal opinion occurred in the Fourth Circuit of the Court of Appeal. Chief Justice Sobeloff
headed the court in overturning years of legal decisions which put in place an appropriate
structure of discriminatory hospital services. At first, the majority opinion was against the
position of the Office of the Attorney General. But after deliberating for several months and
drafting the decision, Sobeloff was able to convince Judge Bryan to join his opinion. Finally,
Sobeloff managed to secure Judges Bryan and Bell to vote in his favor. Of dissenting opinion
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were Judges Boreman and Haynsworth. The court held that the hospitals violated the Fourteenth
and Fifth Amendments because they had a connection with the government through the Hill-
Burton funds. The court
- The opinion of the lower court that was finally overturned in Simkins
The District Court had dismissed the case in April 1963 on ground that the facts of Simkins were
not any different from the previous Easton case, and that the law had not ever been changed to
intervene in the circumstances. Judge Stanley was of the view that Wesley Long and Moses H.
Cone Hospitals were both private entities, and not government hospitals. The judge relied on the
reasoning of Civil Rights Cases to conclude that the two entities had a right to discriminate if
they chose to. The court found that there was no substantial issue of fact. The court granted the
Motion to Dismiss by defendants for lack of jurisdiction by claiming that there was no state
action, and denied the plaintiffs’ motions for summary judgment.
3. The federal law that was highlighted in Simkins v. Moses H. Cone
The Court of Appeals upheld the claim of the defendant that participating in the Hill-Burton
program was in violation of the Fourth and Fifth Amendments of the constitution. The court also
found that the provisions in the initial Hill-Burton Act which stipulated separate-but-equal
hospital services and accommodation were unconstitutional.
4. How the federal law played a role in deciding this case
The court used the Equal Protection Clause of the Fourteenth Amendment to ban racial
discrimination by private entities. The private hospitals which participated in the Hill-Burton
project were linked to both federal and state governments, and were therefore mandated by the
laws prohibiting racial discrimination as provided under the Fifth and Fourteenth Amendment.
The Simkins decision necessitated the revision of precedent established by the 1883 civil rights
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cases, where the interpretation of the Equal Protection clause was only limited to discrimination
by government agencies which were public in nature (Reynolds, 2004).
5. The Constitutional amendments and issues in the case
The court sought to determine whether the two private hospitals were prohibited under the Fifth
and Fourteenth Amendments to the constitution. The Court interpreted the constitutional
provisions as to prohibit discrimination in private entities connected to the government
(Reynolds, 2004).
6. Why the case was limited in its reach
The reach of the case was limited due to the fact that the Supreme Court refused to grant writ of
certiorari, and therefore, only the hospitals which were under construction, or proposed in the
jurisdiction of the Court of Appeals, the Fourth Circuit were validly mandated to racially
integrate services. The countries which fell under this jurisdiction were South Carolina, North
Carolina, West Virginia, Virginia, and Maryland. In addition, the established Hill-Burton
regulations were not applicable to the hospitals which had already utilized federal funds
(Reynolds, 2004).
7. The federal officials and agencies that finally extended the cases’ ruling and how the
cases’ outcome spread across the Nation
The successful outcome of the case triggered the Legal Defense Fund lawyers to use the case
while filing hospital discrimination cases in other circuit courts. The fund, together with state
attorneys, identified hospitals that did not comply to take them up as cases to the courts. The goal
of the lawyers was to ensure the extension of the reach of law to hospitals across the nation and
to compel public opinion on the way the hospitals and other health care facilities failed to
conform to state and national laws and federal regulations (Reynolds, 2004).
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The Civil Rights Act was signed into law in 1964 by then President Lyndon B. Johnson. Out of
pressure, the Department of Health, Education and Welfare (HEW) developed a thorough
compliance program under both the Title VI of the Civil Rights Act and the Hill-Burton
program. HEW drafted new rules for Title VI which prohibited the act of distributing federal
funds to institutions that were discriminatory to minority populations. President Johnson
approved the Title VI provisions and they immediately became effective. Though the goal of the
advocates for zero discrimination was to ensure voluntary conformity to racial integration, the
federal government could also use force by withholding funds from non-compliant institutions.
Through the leadership of Dr Roy, Dr Reginald Hawkins, Dr George Simkins, and Dr Hubert
Eaton, the legal precedent was established nationally to provide for racial integration of
professional societies and hospitals (Reynolds, 2004).
- The case of Simkin makes a big difference in decreasing health inequities because it sets
standards that support behavior that is not discriminatory. However, there are incidences where
people are treated basing on their age, status, and financial position (Basic Health Access, 2013).
References
Basic Health Access. (2013). Health Services for Most Americans Behind by Design.