Coors & Birdsong v. Tennessee Temporary Joint Underwriting Ass'n

485 F. Supp. 563, 1977 U.S. Dist. LEXIS 14822
CourtDistrict Court, W.D. Tennessee
DecidedJuly 26, 1977
DocketNo. C-76-80
StatusPublished

This text of 485 F. Supp. 563 (Coors & Birdsong v. Tennessee Temporary Joint Underwriting Ass'n) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coors & Birdsong v. Tennessee Temporary Joint Underwriting Ass'n, 485 F. Supp. 563, 1977 U.S. Dist. LEXIS 14822 (W.D. Tenn. 1977).

Opinion

ORDER

WELLFORD, District Judge.

Several Memphis-based medical professional associations have filed suit against Tennessee Temporary Joint Underwriting Association (hereafter TTJUA) and its Directors under 42 U.S.C. §§ 1981 and 1983 and the First and Fourteenth Amendments. TTJUA was created by Chapter 350 of the 1975 Tennessee Public Acts, Tenn.Code Ann. 56-4301 through 56-4315, as the exclusive agency for new medical malpractice insurance for Tennessee physicians, effective June 6, 1975. Plaintiffs assert in the complaint that pursuant to findings by the Tennessee Commissioner of Insurance that medical malpractice insurance was not available to Tennessee doctors in the voluntary or private insurance market, TTJUA was established as the sole agency for the writing of such insurance, and that when their policies expired, plaintiffs were forced to obtain coverage through that agency unless they desired to be self-insured. The complaint asserts that TTJUA has refused to write such insurance for those engaged in group practice unless the group itself purchases a separate and additional policy for twenty per cent (20%) of the premiums of all the individual doctors comprising the group or association.

Plaintiffs charge that the practice in issue is “arbitrary and capricious and not based on any increase in risk . and is clearly excessive . not based on any valid claims experience whatsoever.” It is, therefore, claimed that this practice constitutes a taking without compensation and without due process. A separate claim is that defendants have acted wrongfully in requiring a partnership or association to be insured under this procedure before individual partners or members can obtain policies despite a request by plaintiffs to the contrary, and that the practice constitutes “an invidious discrimination . on the basis of their exercise’ of First Amendment rights of freedom of association.” Finally, plaintiffs contend that defendants have violated the statutory scheme itself in establishing the practice and procedure complained about, because it is discriminatory and establishes rates on other than an “actuarially sound basis.”1 [565]*565Plaintiffs assert that more than $60,000 in excess premiums was charged. Plaintiffs have asserted this to be a class action under P.R.Civ.P. 23 and have moved to certify the class.

In their answer, defendants aver that since the filing of the complaint, a certificate of authority to transact business in Tennessee has been issued to a new insurance company formed to write medical malpractice insurance; but tl^sy admit the procedure challenged as to a group or partnership rate requirement as a condition precedent to writing insurance policies for individual association or partnership doctors. It is also admitted that part of this premium goes to the statutorily established “stabilization fund.”

TTJUA was established as a non-profit (nor loss) quasi-public organization to make medical malpractice insurance available for protection of health care providers, to assure the public of availability of protection in case of legitimate malpractice claims at the lowest possible cost.2 During the same time period, efforts also were being made by other state legislatures to provide such insurance in the face of escalating costs and reluctance of the private insurance industry to insure physicians for malpractice. See Hartford Accident Indemnity v. Ingram, 290 N.C. 457, 226 S.E.2d 498 (1976). The statute created TTJUA with its sole and exclusive powers to operate only during the period in which the State Commissioner would certify that a medical malpractice insurance crisis exists, not to exceed two years.

The Court has considered the entire record in this cause, the arguments of counsel, and the memoranda of the parties in support of their positions relative to defendants’ motion to dismiss and/or for summary judgment.

State action, a state nexus, may exist in the creation and operation of TTJUA under the Tennessee law here in question. It is a statutory creation, closely intermingled with state functions, particularly the Commissioner of Insurance. The rationale of Jackson v. Metropolitan Edison Co., 419 U.S. 345, 95 S.Ct. 449, 42 L.Ed.2d 477 (1974), indicates that 42 U.S.C. § 1983 does apply if plaintiffs can show deprivation of a constitutional right by operation of and under color of state law. See Craft v. Memphis Light, Gas & Water Div., 534 F.2d 684 (6th Cir. 1976) (a property interest exists in continuation of utility services.)3 Is there a similar property interest in expectation of obtaining malpractice insurance?

Board of Regents v. Roth, 408 U.S. 564, 92 S.Ct. 2701, 33 L.Ed.2d 548 (1972), dealt with due process requirements in respect to a claimed property interest, in that instance, a job as a state university teacher. To claim an interest protected by the Constitution, he was declared to be required to show “more than a unilateral expectation instead ... a legitimate claim of entitlement . . . ” See Coe v. Bogart, 519 F.2d 10 (6th Cir. 1975). Plaintiffs’ liberty interests are not abridged since they are free to pursue the practice of medicine without insurance protection; they must, instead, show a legitimate claim of entitlement to have malpractice insurance to claim Fourteenth Amendment due process protection. Bolling v. Sharpe, 347 U.S. 497, 74 S.Ct. 693, 98 L.Ed. 884 (1954); Meyer v. Nebraska, 262 U.S. 390, 43 S.Ct. 625, 67 L.Ed. 1042 (1923). Even a requirement imposed by a state-supported hospital that a physician must evidence malpractice insurance protection to be on the hospital staff has been held not to involve sufficient property or liberty interest within the meaning of 42 U.S.C. § 1983 or the Fourteenth Amendment due process standards, [566]*566nor to violate the doctor’s civil rights. Pollock v. Methodist Hospital, 392 F.Supp. 393, 396 (E.D.La.1975). Transfer of a tenured teacher likewise does not involve requisite liberty or property interests. Sullivan v. Brown, 544 F.2d 279 (6th Cir. 1976).

Recent decisions by appellate tribunals, moreover, have indicated that 42 U.S.C. § 1983

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Related

Meyer v. Nebraska
262 U.S. 390 (Supreme Court, 1923)
Bolling v. Sharpe
347 U.S. 497 (Supreme Court, 1954)
Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
Jackson v. Metropolitan Edison Co.
419 U.S. 345 (Supreme Court, 1974)
Bishop v. Wood
426 U.S. 341 (Supreme Court, 1976)
Memphis Light, Gas & Water Division v. Craft
436 U.S. 1 (Supreme Court, 1978)
Linda Kay Sullivan v. George Brown
544 F.2d 279 (Sixth Circuit, 1976)
Hartford Accident & Indemnity Co. v. Ingram
226 S.E.2d 498 (Supreme Court of North Carolina, 1976)
Pollock v. Methodist Hospital
392 F. Supp. 393 (E.D. Louisiana, 1975)

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Bluebook (online)
485 F. Supp. 563, 1977 U.S. Dist. LEXIS 14822, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coors-birdsong-v-tennessee-temporary-joint-underwriting-assn-tnwd-1977.