Law School Case Brief
Campbell v. Mincey - 413 F. Supp. 16 (N.D. Miss. 1975)
To establish an equal protection violation, plaintiffs must show that the classification and consequent dissimilar treatment fail to advance any legitimate state interest. The Equal Protection Clause does not prohibit discrimination between persons or groups of persons; it precludes only irrational discrimination.
Plaintiffs mother and son, Hattie Mae Campbell and her infant son, Frederick, filed an action against defendants, R. J. Mincey, chairman of the Board of Trustees of the Marshall County Hospital, Talmage Edwards, J.W. Cocke, Arvern Newson, J.A. Hale, William Sidney Payne and Billy Williams, members of the Board of Trustees of the Marshall County Hospital, James Hall, administrator of the Marshall County Hospital, Leonard Wright, Chief of Staff of the Marshall County Hospital, and Dollie Porter, Director of Nursing of the Marshall County Hospita. Hattie, a young, poor African-American woman, alleged that she was denied admission to the Marshall County Hospital and its emergency room for the delivery of Frederick, who was not due for another six weeks, because of her race and financial condition. Rather, Hattie gave birth to Frederick in a car in the parking lot of the Marshall County Hospital and yet, still refused her admission, instead giving Hattie a sheet to wrap the baby in and arrange for an ambulance to take Hattie and Frederick to another hospital a few miles down the road. The Marshall County Hospital sought summary judgment, arguing that it had a policy requiring that only a local physician could admit a patient to the hospital. Hattie argued that the Hospital's policy, which resulted in the refusal of treatment, was an unreasonable restriction upon the use of a public hospital by herself and other similarly-situated individuals.
Did the hospital policy requiring a local physician to admit a patient violate the equal protections clause?
The federal district court dismissed the mother's complaint that alleged that the board's policy, which required that a local physician admit a patient, placed an unreasonable restriction upon the use of a public hospital on the basis of race and financial resources. The court found that the mother had been a patient of the hospital on the occasion of a previous pregnancy and that the emergency room was used more frequently by blacks than by whites. The court also found that a large portion of the patients treated at the hospital were Medicaid patients. Thus, the court found no basis for the mother's contention that she was refused treatment because she was black or indigent.
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