Pennsylvania’s Workers’ Compensation Act permits insurers and self-insured employers to withhold payment for medical treatment pending a review of whether the treatment is "reasonable" and "necessary." Several employees whose benefits had been withheld, along with organizations representing such employees, sued various state officials and private insurers on the grounds that withholding the benefits without first affording the employees notice and an opportunity to be heard violated the Due Process Clause. The Third Circuit upheld their claims, but the Supreme Court reversed. It held that (1) the insurers are not state actors because their decisions to withhold payment are not "fairly attributable" to the state and (2) given the terms of the Pennsylvania statute, employees have no property interest in payments for medical treatment until they have established that the treatment is "reasonable" and "necessary."The NAM filed an amicus brief supporting this appeal, and then a brief on the merits supporting the ultimate result. The Third Circuit's ruling threatened to tie up utilization review and medical care cost containment in workers' compensation cases, increasing costs.