Court Dismisses Free Exercise Claims Against Private Actors

In Palm v. Sisters of Charity Health System, 2008 U.S. Dist. LEXIS 42287 (D ME, May 29, 2008), a Maine federal magistrate judge recommended dismissal of a claim that doctors were discriminating against believers in the "Bible Code" when they involuntarily committed plaintiff to a private hospital. The court said that claims of a conspiracy to violate free exercise rights brought under 42 U.S.C. 1985(3) and 42 U.S.C. 1986, as well as civil rights claims under 42 U.S.C. 1983, should be dismissed because defendants are not state actors.