William Allen Spencer v. Bumyong Lee, M.D., and St. Elizabeth Hospital

Disagreeing with the majority’s conclusion that the actions of the defendants in committing Spencer to St. Elizabeth Hospital necessarily cannot constitute state action, I respectfully dissent from the majority’s holding. In order to determine whether the defendants’ roles in the involuntary commitment of the plaintiff qualify as state action such that the defendants may be subject to liability under 42 U.S.C. § 1983, it is necessary to elaborate on the majority’s discussion of the statutory authority for defendants’ conduct.

Involuntary commitment to a mental health institution may be…