Everything you need to know about ranked-choice voting in one spot. Click to learn more!

Coats v. Sampson County Memorial Hospital, Inc.

From Ballotpedia
Jump to: navigation, search

BP-Initials-UPDATED.png This Ballotpedia article needs to be updated.
This Ballotpedia article is currently under review by Ballotpedia staff as it may contain out-of-date information. Please email us if you would like to suggest an update.



Litigation.png

This Open Records and Transparency Project article is a sprout. You can help us collect information about this case, and other important FOIA cases across the country, by expanding this article.

Coatsvs.Sampson County Memorial Hospital, Inc.
Number: 141 S.E.2d 490
Year: 1965
State: North Carolina
Court: North Carolina Supreme Court
Other lawsuits in North Carolina
Other lawsuits in 1965
Precedents include:
This case established two important precedents:
  • That private agencies who serve a public function are considered agents of the public bodies who would normally hold that responsibility.
  • Operating hospitals is in fact a public, governmental function and can render a semi-private county hospital a public body.
Sunshine Laws
How to Make Records Requests
Sunshine Litigation
Sorted by State, Year and Topic
Sunshine Nuances
Deliberative Process Exemption


Coats v. Sampson County Memorial Hospital, Inc. was a case before the North Carolina Supreme Court in 1965 concerning the definition of public body.

Important precedents

This case established two important precedents:

  • That private agencies who serve a public function are considered agents of the public bodies who would normally hold that responsibility.
  • Operating hospitals is in fact a public, governmental function and can render a semi-private county hospital a public body.[1]

Background

  • This case arose from a liability litigation against Sampson County Memorial Hospital. The core contention of the case was whether Sampson County Memorial Hospital was considered an agent of the county and whether or not the county was liable for the actions of the hospital. If the hospital was an agent of the county, then the trial would need relocated to Sampson County.[1]

Ruling of the court

The Supreme Court determined that the Hospital did in fact fall under the definition of public agency and was thus under the jurisdiction of the legal process relating to municipalities. The court determined that the functions of maintaining and operating a hos;ital were in fact governmental functions. The court went on to determine that the county had delegated those functions to the operating managers of the hospital. This rendered the hospital an agent of the county.[1]


Associated cases

See also

External links

Footnotes