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Research question · Under review

A procedural barrier is treated as a universal absence of remedy.

NEW: Rawson v. Recovery Innovations,9thCir.2020, reversed summary judgment on state-action grounds. Under those facts, a private psychiatric provider acted under color of state law. Wrongful detention, forced medication and misleading the court were the underlying allegations, not all finally proved by that appellate ruling. This qualifies any blanket claim that private facilities cannot face federal civil-rights claims. No safety-whistleblowing trigger is established. Later merits outcome remains unlocated. Source: https://law.justia.com/cases/federal/appellate-courts/ca9/19-35520/19-35520-2020-09-09.html