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But Shields sees a clear way forward for everyone, and it involves assigning no blame, and laying on no one the psychic burden of choosing between two ways of giving oneself cancer

The basic rule is that state action exists if the dispute is tort-related or if the rights arise from a state statute, but does not exist if the dispute arises from a contractual relationship or involves common-law property rights, unless a non-judicial state actor is involved or if racial discrimination is implicated. [If you want a way to make Shelley seem less weird, Carol Rose has a great explanation of why enforcing some contracts implicates the state in unconstitutional positions, e.g., that racial discrimination is acceptable

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