Braun v. Ada County

643 P.2d 1071, 102 Idaho 901, 1982 Ida. LEXIS 236
CourtIdaho Supreme Court
DecidedApril 7, 1982
Docket13526
StatusPublished
Cited by18 cases

This text of 643 P.2d 1071 (Braun v. Ada County) is published on Counsel Stack Legal Research, covering Idaho Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Braun v. Ada County, 643 P.2d 1071, 102 Idaho 901, 1982 Ida. LEXIS 236 (Idaho 1982).

Opinions

BAKES, Chief Justice.

On October 30, 1978, appellant Marcia Braun gave birth to a son who was born prematurely and who required emergency treatment. Both the birth and the emergency treatment occurred at St. Luke’s Hospital, Boise, Idaho. On November 21, 1978, the appellant applied to Ada County Emergency Welfare for financial assistance with the hospital bill which totalled $1,475.67. On January 15, 1979, the board of Ada County Commissioners denied appellant’s application. Pursuant to I.C. § 31— 3505, appellant requested and obtained a hearing before the commissioners on the matter. Following a hearing on May 22, 1979, the commissioners concluded that appellant was not medically indigent under I.C. § 31-3502(1) in that she still had other resources available for the satisfaction of the hospital charges in the form of St. Luke’s Hospital’s uncompensated services obligation under the federal Hill-Burton Act, 42 U.S.C. § 291c(eX2). Consequently, appellant’s application for assistance was again denied.

Braun appealed to the District Court for the Fourth Judicial District. The parties stipulated that appellant would be medically indigent under I.C. § 31-3502(1), and therefore entitled to county aid, except for St. Luke’s unsatisfied Hill-Burton obligation. The district court upheld the decision of the commissioners denying assistance, and appellant has further appealed to this Court.

Idaho Code title 31, chapters 34 and 35, establish the framework through which the state provides needed medical care to those persons who otherwise would be financially unable to obtain it. I.C. § 31-3406 sets forth the county’s obligation to aid the medically indigent. It states:

“31-3406. PROVISION FOR RELIEF. —The county commissioners of such county shall, after the filing of the application and findings of the clerk as aforesaid, if in their judgment the applicant is medically indigent make such provisions for his relief, or pay for his hospitalization, as may be necessary under the circumstances.”

In order to qualify for county aid under I.C. § 31-3406, a person claiming medical indigency must meet the following definition found at I.C. § 31-3502(1):

“31-3502. DEFINITIONS. — As used in this chapter, and chapter 34, title 31, Idaho Code, the terms defined in this section shall have the following meaning, unless the context clearly indicates another meaning:
[903]*903“(1) ‘Medically indigent’ means any person who is in need of hospitalization and who, if an adult, together with his or her spouse, or whose parents or guardian if a minor, does not have income and other resources available to him from whatever source which shall be sufficient to enable the person to pay for necessary medical services.” (Emphasis added.)

Ada County argues, and the district court held, that appellant does not meet this definition in that resources to satisfy the medical bills were available in the form of St. Luke’s Hospital’s uncompensated services obligation under the federal Hill-Burton Act.

Briefly, the Hill-Burton Act, 42 U.S.C. 291 et seq., establishes a program of grants, loans and loan guarantees to finance the construction and modernization of hospitals and other medical facilities. Generally, in order to qualify for Hill-Burton funds, a hospital must give assurance that it will, among other things, make available “a reasonable volume of services to persons unable to pay therefor .... ” 42 U.S.C. § 291c(eX2); 42 C.F.R. § 53.111. Thereafter, a hospital will be deemed to be in presumptive compliance with its obligation under the assurance if each year for twenty years it provides to qualifying applicants medical services without charge in an amount not less than the lesser of 3% of operating costs or 10% of all federal assistance provided to the facility under the act. 42 C.F.R. 53.111(d). In order for a hospital to obtain credit toward the yearly uncompensated services figure, the cost of services “written off” may not include any amount which the recipient of services “has received, or is entitled to receive ... under a governmental program.” 42 C.F.R. 53.-lll(f)(2)(i). It is thus argued by appellant that since the Hill-Burton uncompensated services obligation does not cover medical services otherwise payable through governmental programs, including Ada County’s obligations under Idaho Code title 31, chapters 34 and 35, the Hill-Burton obligation is meant to be a last resort and cannot be included as a resource of appellant to preclude her from obtaining county aid for her medical expenses.

Despite appellant’s argument, the court below determined that Ada County, rather than St. Luke’s Hill-Burton uncompensated services obligation, constituted the true last resort for satisfying the needs of the medically indigent. In reaching its decision, the court reviewed three statutes, I.C. §§ 31-3502(1), -3508,1 -3509,2 and stated: “The accumulative effect of these statutes is a declaration by the legislature that the county shall be the last resort following any other source or credit available to finance the care. While the legislature has not specifically mentioned the Hill-Burton obligation, it has placed the county obligation behind ‘other resources available to him from whatever source’ .... ” For the reasons discussed below, we conclude that the district court’s interpretation of the above statutes was overbroad.

I.C. § 31-3501 (Supp.1979) constitutes the legislature’s declaration of policy concerning the provision of medical care for the indigent sick at the time this case arose. It states the following:

“31-3501. DECLARATION OF POLICY. — In order to safeguard the public health, safety and welfare, and to provide [904]*904suitable facilities and provisions for the care and hospitalization of indigent persons in this state, and to provide for the payment thereof, the respective counties of this state shall have the duties and powers as hereinafter provided.” (Emphasis added.)

As indicated by the italicized portion of I.C. § 31-3501, an additional objective of the relevant statutes is to assure that medical facilities receive payment for the services rendered by them.3 Such an objective goes hand in hand with the stated intent of providing “suitable facilities and provisions for the care and hospitalization of indigent persons,” since the financial solvency and stability of medical facilities is an important aspect of assuring that the desired medical services and facilities are available.

A review of the three statutes discussed by the district court further supports the legislature’s objective of assuring that medical facilities obtain payment for services rendered to indigents. I.C. § 31-3502(1) speaks in terms of a medically indigent person being one who has insufficient resources “to pay

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Braun v. Ada County
643 P.2d 1071 (Idaho Supreme Court, 1982)

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Bluebook (online)
643 P.2d 1071, 102 Idaho 901, 1982 Ida. LEXIS 236, Counsel Stack Legal Research, https://law.counselstack.com/opinion/braun-v-ada-county-idaho-1982.