Introduction
The U.S. healthcare industry is highly governed by law. Thus, there are legal principles spelt out in federal and state laws that medical practitioners in the U.S. should observe. When legal issues that pertain to healthcare administration arise, U.S. courts may come in to help with interpretation of the relevant laws. Thus, the Case of Simkins v Moses H.Cone Memorial Hospital (1963) demonstrates the role of the U.S. legal system in administration of healthcare.
At what Level of the Judicial Court System did this Legal Opinion Occur?
The opinion of judge Sobeloff occurred at a U.S. Court of Appeals. Specifically, the U.S. Court of Appeals Fourth Circuit heard the Case of Simkins v Moses H.Cone Memorial Hospital (1963). As demonstrated in the case, “a party dissatisfied with a decision of a lower court”, such as a U.S. District Court, may seek legal redress at a U.S. Court of Appeals (United States Courts, n.d., para. 5).
What was the Opinion of the Lower Court that was Finally Overturned in Simkins?
The opinion of the lower court was that the hospital in question had not been fulfilling a state function (Reynolds, 2004, p. 712). Having found no evidence to the effect that the hospital had used Hill-Burton funds, the lower court ruled in favor of the defendant. Use of Hill-Burton funds would have served as evidence of state action in operations of the hospital. In turn, evidence of state action would have warranted the court’s interpretation of constitutional provisions that applied to the case.
Explain at Least One of the Federal Laws that was Highlighted in Simkins v. Moses H. Cone
The Hospital Survey and Construction Act (1946) came into play in the Simkins v Moses H. Cone hospital case. Commonly referred to as “the Hill-Burton Act”, the federal law was passed to allow the federal government to fund construction of state health facilities and hospitals. In addition, the law provided for the conducting of federal-funded surveys to determine health care needs of specific, hospitals and population groups. However, the Hill-Burton Act contained the “separate but equal clause”, whose constitutionality was later challenged in court (Reynolds, 2004, p. 711).
How did the Federal Law Play a Role in Deciding this Case?
In the case of Simkins v Moses H.Cone Memorial Hospital, the Hill-Burton Act provided a legal basis for invoking the 5th and 14th amendments of the U.S. constitution to offer protection against hospital discrimination. For starters, the law allowed the federal government to get involved in operations of private hospitals. Thus, once a hospital participated in a federal program, such as the Hill-Burton, it was bound by law to integrate its services.
In deciding the case, the U.S Court of Appeals established state involvement in the running of Moses H. Cone Memorial Hospital. Furthermore, the court considered the fact that the hospital practiced discrimination despite having used federal aid as provided for under the Hill-Burton Act. Thus, the court found use of federal help in a discriminatory manner to have been in contravention of the U.S constitution.
Identify and Discuss the Constitutional Amendments and Issues in the Case
The 5th and 14th amendments of the U.S. Constitution were appreciably applied in the case. The amendments prohibited the federal and state governments from discriminating. Various constitutional issues were raised in the case of Simkins v Moses H.Cone Memorial Hospital. For instance, it was critical to determine whether or not the hospital in question had become an instrumentality of the government by permitting federal involvement in its operations (“Constitutional Law,” 1964).
It was also important to determine if the federal government discriminated by funding a medical facility that practiced discrimination. Similarly, was the “separate but equal clause” of the Hill-Burton Act in line with the 5th and 14th amendments of the U.S. Constitution? Answers to the issues raised determined whether or not Moses H.Cone Memorial Hospital had violated the law by practicing discrimination.
Explain why the Case had a Limited Reach
The Simkins v. Moses H. Cone Memorial Hospital case had a limited reach because the U.S. Supreme Court declined to review it. The case would have produced a far-reaching legal precedent had it gone through the Supreme Court successfully. At the Supreme Court level, it would have been possible for other U.S. Courts of Appeals to refer to the case when deciding on similar disputes. However, the Simkins v. Moses H. Cone Memorial Hospital case only reached an appellate court level. Thus, the outcome of the case could not influence judicial decisions that were made outside the jurisdiction of the Fourth Circuit Court (Reynolds, 2004, p.714).
Identify the Federal Official and Agency that Finally Extended the Cases’ Ruling
The U.S. Court of Appeal Fourth Circuit was the federal agency that finally extended the cases’ reach. Although judge Sobeloff was not the court’s chief justice during the case of Cypress v Newport News Hospital Association, he was the federal official who wrote the legal opinion that outlawed all forms of hospital discrimination. Thus, judge Sobeloff was instrumental in the expansion of the Simkins v. Moses H. Cone Memorial Hospital case’s reach.
Identify how the Cases’ Outcome Spread Across the Nation
The U.S Court of Appeals Fourth Circuit gave the Simkins v. Moses H. Cone Memorial Hospital case an expanded reach by referring to it in nearly every hospital racial discrimination case it handled for 20 years that followed (Reynolds, 2004, p.718). Furthermore, the case was instrumental in design of Hill-Burton regulations that reinforced nationwide hospital integration. Equally important, the case formed a solid background for passage of the Civil Rights Act (1964), which outlawed major forms of discrimination on a national scale (Reynolds, 2004, p.718).
Discuss why you the Think the Simkins v. Moses H. Cone Memorial Hospital Case Makes or Fails to Make a Big Difference Today
The Simkins v. Moses H. Cone Memorial Hospital case did bring about a significant drop in hospital discrimination over time. The case helped lay a solid groundwork for implementation of the Hill-Burton program. Thus, it is accurate to state that the success of federal programs such as Medicare in modern hospitals traces its roots to the Simkins v. Moses H. Cone Memorial Hospital case. A case in point is the Medicare prescription drug law seeks to control a wide array of practices by pharmaceutical companies to safeguard patients’ interests (Stiller & Weinstock, 2006, p.8).
However, the U.S. healthcare system has not achieved the level of equity envisioned by law. Many poor Americans lack access to good healthcare as a result of poor design of the entire healthcare system. Today, many hospitals grapple with significant shortfalls of primary healthcare specialists such as nurses (Bowman, 2013, para. 11).
As such, while the healthcare law significantly safeguards practitioners’ and patients’ rights, significant proportions of the U.S. population cannot access optimal health care. Today, many patients (including those from minority groups) continue to face challenges such as poor education, limited financial options and ignorance as they pursue effective medication. However, hospital discrimination is no longer a legally sanctioned practice in the entire U.S.
References
Bowman, R.C. (2013). Is the Institute of Medicine Design Waking Up? Web.
Constitutional Law: Discrimination by Private Hospitals Participating in Hill-Burton Program Held to be Violation of Fifth and Fourteenth Amendments. (1964). Duke Law Journal, 1964 (908), 908-914. Web.
Reynolds, P.P. (2004). Professional and Hospital Discrimination and the US Court of Appeals Fourth Circuit 1956-1967. American Journal of Public Health, 94(5), 710-720. Web.
Stiller, J.A., & Weinstock, J.L. (2006). Introduction to Health Law. Web.
Tenant (n.d.). Introduction to the United States Legal System. Web.
United States Courts (n.d.). Comparing State and Federal Courts. Web.
