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Bioethics Keyed to Clark, 9th Ed.
Bryan v. Koch
Citation:
627 F.2d 612 (1980)Facts
In 1979, facing financial difficulties, New York City appointed a Health Policy Task Force to examine ways of reducing costly excess hospital capacity. The Task Force recommended closing two hospitals, including Sydenham Hospital in Harlem, which served a population that was 98% minority. Sydenham was the smallest of the City’s 13 acute care municipal hospitals with an average daily in-patient caseload of only 93 patients. It had a high operating deficit, an obsolete physical plant needing costly renovation, and was located within 30 minutes of another municipal hospital (Harlem Hospital) and five voluntary hospitals. The plaintiffs argued that the closure would have a disproportionate impact on minority residents and that the City failed to consider less discriminatory alternatives to achieve its cost-saving goals. The City maintained that the decision was based on objective criteria related to efficiency and that adequate alternative healthcare facilities were available for Sydenham’s patients.
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