Campbell v. Mincey

In the early morning of March 21, 1974, Hattie Mae Campbell (plaintiff) arrived at the Marshall County Hospital (the hospital) with labor contractions. A hospital nurse observed that Campbell’s contractions were occurring every five minutes and that her water had not broken. In accordance with the hospital’s policy requiring that a hospital physician authorize the nonemergency admittance of a patient, the nurse told Campbell to go to the hospital where she had received her prenatal care and confirmed with the emergency room physician that this was the correct course of action. The hospital had enacted this policy because no physicians employed by the hospital worked between 6:30 p.m. and 7:00 a.m. During this time, the emergency room doctors were associated with the University of Tennessee rather than with the hospital. By requiring that a hospital physician authorize nonemergency admittances, the hospital could ensure that there would be a hospital physician available for any follow-ups or additional treatment after the night shift. Campbell followed the nurse’s instructions and left the hospital. Campbell then gave birth in the hospital’s parking lot. Although Campbell lacked any medical assistance during the birth, neither she nor her baby suffered any injuries. Campbell filed an action in federal district court against the hospital’s board of trustees, administrator, chief of staff, and director of nursing (collectively, the hospital personnel) (defendants). Campbell claimed that the hospital’s policy violated common tort law and her equal-protection rights guaranteed by the United States Constitution. Campbell claimed that she was not admitted into the hospital because of her race and her indigent status but offered no evidence to support her allegations. The district court reviewed the case.