In American Mfgs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40 (1999), the court determined whether private insurers were subject to the constraints of the Fourteenth Amendment. The court stated "that state action requires both an alleged constitutional deprivation 'caused by the exercise of some right or privilege created by the State or by a rule of conduct imposed by the State or by a person for whom the State is responsible', and that 'the party charged with the deprivation must be a person who may fairly be said to be a state actor.'" Id. at 50.