Hui v. Castaneda
Issues
Whether a lawsuit claiming that federal employees of the Public Health Service committed medical negligence may be filed under a federal statute that makes the United States the defendant, or whether the employees may be sued personally for violating the Constitution.
This case involves a lawsuit brought by the estate of decedent, Mr. Castaneda, against two Public Health Service (“PHS”) officials (collectively, the “Petitioners”) for failing to provide proper medical care to Mr. Castaneda during his custody in a state immigration facility. Mr. Castaneda had a growing, fungating lesion on his penis but was denied a simple skin biopsy from PHS officials. Consequently, Mr. Castaneda died of penile cancer at the age of 36. At issue here is whether the Federal Employees Liability Reform and Tort Compensation Act of 1988 (“FTCA”), providing that federal employees are not protected from constitutional tort claims, extends to 422 U.S.C. § 233(a) of the Emergency Health Personnel Act, which covers PHS officials. The Supreme Court’s decision in this case may significantly affect the extent to which prisoners may seek recourse if denied constitutionally guaranteed access to adequate medical care while under state custody. This case may also affect public health personnel: while a decision for Respondents may discourage federal employees from committing constitutional violations, it may also negatively impact employment.
Questions as Framed for the Court by the Parties
(1) Does 42 U.S.C. § 233(a) make the Federal Tort Claims Act the exclusive remedy for claims arising from medical care and related functions provided by Public Health Service personnel, thus barring Bivens actions?
This case centers on interpreting the scope of immunity afforded to personal health service officials within the context of 42 U.S.C. § 233(a) of the Emergency Health Personnel Act. This statute covers the employees of the Public Health Service, and 28 U.S.C.