Bryan v. Koch
United States Court of Appeals for the Second Circuit
627 F.2d 612 (2d Cir. 1980)
New York City, under Mayor Ed Koch (defendant), decided to close one of its 17 municipal hospitals to reduce costs and improve efficiency; a city task force identified the hospital as having high operating deficits, an obsolete facility, and proximity to other municipal hospitals offering comparable or broader services. The hospital served a population that was 98% minority, and plaintiffs argued that even though the specific hospital was an appropriate one to close, the closure decision violated federal civil rights law because of its disproportionate racial impact; the trial court denied a preliminary injunction, and plaintiffs appealed.
Whether a city's decision to close a public hospital for cost-saving and efficiency reasons is justified under federal civil rights law even when the closure disproportionately affects a minority population.