Craft v. Vanderbilt University

18 F. Supp. 2d 786 (1998)

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Craft v. Vanderbilt University

United States District Court for the Middle District of Tennessee
18 F. Supp. 2d 786 (1998)

Facts

From 1945 until 1947, Vanderbilt University, the State of Tennessee, and the Rockefeller Foundation (defendants) conducted experiments as part of a joint venture known as the Tennessee-Vanderbilt Nutrition Project (TVNP). The experiments involved administering radioactive iron to pregnant women to track iron absorption. Pregnant women were given “cocktails” containing radioactive iron but were not notified that the drinks contained radioactive material, were not informed of the risks associated with the experiments, and were not allowed to refuse participation. Employees from both Vanderbilt and the State of Tennessee Department of Health were involved in the project. The two entities shared facilities and resources and published articles based on their research. The Rockefeller Foundation, as a significant funding source of the TVNP, placed its employees in positions of leadership within the project. The TVNP embraced the rules and suggestions of the Rockefeller Foundation. Women who sought prenatal care from Vanderbilt University during the relevant period and their children exposed to radiation as part of the experiments (plaintiffs) filed a lawsuit, alleging federal civil rights and state tort claims. Vanderbilt, the State of Tennessee, and the Rockefeller Foundation filed motions to dismiss or for summary judgment, arguing that the claims must be dismissed due to a lack of state action.

Rule of Law

Issue

Holding and Reasoning (Nixon, C.J.)

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