Mitchell v. Washington

George Mitchell (plaintiff), an African American male, was diagnosed with Hepatitis C in 2000. In 2003, Mitchell was civilly committed to a special center as a sexually violent predator by Washington State (defendant). Mitchell received treatment for Hepatitis C at the center and decided to try to lose weight before undergoing treatment with interferon and ribavirin (IR treatment). In 2009, Mitchell met with Dr. Bell (defendant), the center supervisor, and Mitchell requested the IR treatment because he believed his condition was deteriorating. Bell explained that the IR treatment for Mitchell’s genotype had not proven successful for African American males. Bell also reviewed Mitchell’s liver-biopsy results and informed Mitchell that his Hepatitis C had not worsened enough to justify the IR treatment’s side effects. Bell did not recommend the IR treatment at that time based on both of these factors. Bell did not justify his use of the racial classification nor show that any justification was narrowly tailored. Bell did not understand that the use of race-related success-of-treatment data as a factor would be unconstitutional. In 2012, Mitchell brought an action against the state, Bell, and center officials (state officials) (defendants). Mitchell claimed that Bell’s consideration of race in the denial of the IR treatment violated the Equal Protection Clause of the Fourteenth Amendment. The state officials moved for summary judgment on the equal-protection-violation claim. The case was referred to a magistrate, who found that the state officials were entitled to qualified immunity shielding them from liability because there was no violation of Mitchell’s constitutional rights. The district court adopted the magistrate’s recommendation and granted summary judgment to the state officials. Mitchell appealed.