Introduction

The consolidated appeals of Harry T. Krynicky, Jr. v. University of Pittsburgh and Rosemary Schier v. Temple University present a pivotal examination of the "state action" requirement under 42 U.S.C. § 1983. These cases evaluate whether recent Supreme Court decisions known as the "Lugar trilogy" have overruled the Third Circuit's precedent in BRADEN v. UNIVERSITY OF PITTSBURGH, which established that certain universities qualify as state actors. The appellants, Krynicky and Schier, challenged their respective universities' employment decisions, alleging violations of the Fourteenth Amendment rights facilitated by the institutions' ties to the state of Pennsylvania.

Summary of the Judgment

The United States Court of Appeals for the Third Circuit examined whether the Supreme Court's decisions in the Lugar trilogy — comprising Lieu v. Edmondson Oil Co., Inc., RENDELL-BAKER v. KOHN, and BLUM v. YARETSKY — had effectively overruled the Third Circuit's earlier decision in BRADEN v. UNIVERSITY OF PITTSBURGH. In Braden, the Court had held that the University of Pittsburgh and, by extension, Temple University, were "state actors" due to their symbiotic relationship with the Commonwealth of Pennsylvania.

Contrary to the appellants' claims, the Court determined that the Lugar trilogy did not override the symbiotic relationship established in Braden. As a result, the Court reversed the district court's judgment in Krynicky's case, affirming that the University of Pittsburgh acts under color of state law. Conversely, the judgment in Schier's case was affirmed, recognizing her claims against Temple University as falling within the scope of § 1983 due to the institutions' state-related status.

Analysis

Precedents Cited

The judgment extensively analyzes several key precedents:

• BRADEN v. UNIVERSITY OF PITTSBURGH: Established that the University of Pittsburgh, due to its interdependent relationship with the state, qualifies as a state actor under § 1983.
• Lugar Trilogy: Comprising Lieu v. Edmondson Oil Co., Inc., RENDELL-BAKER v. KOHN, and BLUM v. YARETSKY, these cases examined the breadth of state action, ultimately finding that mere financial contributions and regulation do not necessarily convert private entities into state actors.
• Burton v. Wilmington Parking Authority: Introduced the "symbiotic relationship" test, determining state action based on mutual benefits and interdependence between the state and the private entity.
• JACKSON v. METROPOLITAN EDISON CO.: Employed the "nexus" test to evaluate the closeness of the relationship between state and private entities.

The Third Circuit reaffirmed that the specific statutory relationships governing the University of Pittsburgh and Temple University demonstrate a closer integration with the state than those considered in the Lugar trilogy cases.

Legal Reasoning

The Court delved into the "state action" requirement, emphasizing that constitutional protections under § 1983 are only applicable when actions are attributable to the state. The pivotal factor was the "symbiotic relationship" between the universities and the Commonwealth, characterized by:

• Significant state financial support and governing influence.
• State-appointed trustees, ensuring state participation in governance.
• Obligations to comply with state-mandated regulations and reporting requirements.

In distinguishing the current cases from the Lugar trilogy, the Court noted that the universities' structural integration with the state surpassed the financial and regulatory relationships in the Supreme Court's trilogy, thereby maintaining the symbiotic relationship test's applicability.

Impact

This judgment upholds the Third Circuit's precedent that certain state-related universities are subject to constitutional scrutiny under § 1983 due to their intertwined relationships with the state. The decision ensures that employment decisions and other actions by these institutions can be challenged as state actions, thereby expanding the scope of civil rights protections within higher education institutions in Pennsylvania. Future cases involving state-related universities will likely reference this judgment to determine the extent of state action applicability.

Complex Concepts Simplified

State Action

State Action refers to actions taken by government entities or individuals acting on behalf of the government. Under § 1983, only actions attributable to the state can be challenged for constitutional violations.

Symbiotic Relationship Test

The Burton test determines state action based on mutual dependence between the state and a private entity. If the state is so intertwined with the private entity that their actions are interdependent, the private entity's actions may be treated as state actions.

Symbiotic vs. Nexus Test

The Symbiotic Relationship Test assesses mutual benefits and interdependence between the state and the entity, whereas the Nexus Test examines the closeness of the relationship without necessarily requiring mutual dependence.

Conclusion

The Third Circuit's decision in Krynicky v. University of Pittsburgh and Schier v. Temple University reaffirms that certain state-related universities operate under state authority due to their symbiotic relationships with the Commonwealth of Pennsylvania. By upholding the precedent set in BRADEN v. UNIVERSITY OF PITTSBURGH, the Court emphasizes that the structural and functional integration of these institutions with the state government subjects their actions to constitutional scrutiny under § 1983. This outcome ensures that employees of state-related universities have the necessary avenues to challenge potential violations of their constitutional rights, thereby reinforcing the protections afforded by the Fourteenth Amendment.