Chrisman v. Sisters of St. Joseph of Peace involved a challenge to a hospital’s refusal to perform a sterilization procedure on the grounds that the hospital received federal funds, and, therefore acted under color of state law. The plaintiff in this case alleged that hospitals receiving federal funds under the Hill-Burton Act were state actors by virtue of their receipt of such funds, and thus could not make medical decisions on the basis of religious belief without violating the Establishment Clause. The U.S. Court of Appeals for the Ninth Circuit reviewed the language of the Hill-Burton Act and noted that the statute explicitly stated Congress’s intent that receipt of funds under the Act would not make private hospitals state actors for purposes of Establishment Clause challenges. The law reflected Congress’s desire that religious hospitals take the federal funds without concern that they would then be required to perform procedures inconsistent with their religious beliefs. The court thus dismissed the case on the grounds that Congress barred Establishment Clause challenges based solely on the receipt of Hill-Burton funds.
Opens in a new window