County of Alameda v. State Board of Control

14 Cal. App. 4th 1096, 18 Cal. Rptr. 2d 487, 93 Daily Journal DAR 4224, 1993 Cal. App. LEXIS 360
CourtCalifornia Court of Appeal
DecidedApril 1, 1993
DocketA055071
StatusPublished
Cited by16 cases

This text of 14 Cal. App. 4th 1096 (County of Alameda v. State Board of Control) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
County of Alameda v. State Board of Control, 14 Cal. App. 4th 1096, 18 Cal. Rptr. 2d 487, 93 Daily Journal DAR 4224, 1993 Cal. App. LEXIS 360 (Cal. Ct. App. 1993).

Opinion

Opinion

STEIN, J.

The State Board of Control and several of its members (hereinafter collectively referred to as the Board) appeal from a judgment compelling the Board to deem the cost of medical services provided to indigent crime victims at Highland General Hospital in the County of Alameda, a “pecuniary loss” as defined by Government Code section 13960, subdivision (d).

We will hold that neither the County of Alameda nor Don Perata, as a member of the board of supervisors and a county taxpayer, has standing to assert the claims of medically indigent crime victims for compensation from the Restitution Fund. We will further hold that the trial court erred in finding that medically indigent crime victims, who are provided medical services by the county hospital pursuant to Welfare and Institutions Code section 17000, have suffered a “pecuniary loss” within the meaning of Government Code sections 13959 and 13960.

Facts

On June 1, 1989, the County of Alameda and Don Perata, chairman of the county board of supervisors (hereinafter collectively referred to as the County) filed this complaint seeking injunctive and declaratory relief against the Board. The Board initially demurred to the complaint on the ground that the County lacked standing to assert the indigent crime victims’ claims for payment from the Restitution Fund. 1 The court overruled the demurrer, and on September 12, 1989, the Board filed its answer.

The underlying facts are not in dispute:

Highland General Hospital is a public hospital owned and operated by the County. Welfare and Institutions Code section 17000 imposes upon the County an obligation to provide medical care to the indigent. Highland General Hospital annually receives approximately $15 million from the State of California through the Medically Indigent Services Account to defray the cost of providing medical care to these indigent patients. (See Welf. & Inst. Code, §§ 16702 and 16703.)

*1101 When a patient is admitted to Highland General Hospital for treatment, the hospital staff typically makes a determination as to the patient’s ability to pay. As the court explained in its statement of decision and order: “The first step in this process is to determine possible third-party payment sources, such as private health insurance, Medi-Cal, Medicare, Veterans’ benefits, or some other ‘third-party recovery’ source. If the patient has no such source of coverage, hospital staff proceed to assess the patient’s ability to pay a share of cost according to County Medical Services Program (‘CMSP’) guidelines, focussing on the monthly income of the patient’s household. For patients determined to be ‘indigent’ under these guidelines, the Hospital’s practice is to write off 100 percent of the hospital bill.” Pursuant to Welfare and Institutions Code section 17403, the hospital has the right to assert future claims against these patients, if they subsequently acquire sufficient property to pay for the unpaid portion of the medical services they received and still meet their basic living expenses.

“If, however, the patient appears to be the victim of a crime, hospital staff do not attempt to assess the patient’s monthly income or ability to pay. Instead, they view the [Restitution Fund] as a potential third-party recovery source and assist the patient in filing a claim for reimbursement. . . .”

“The practice of [the Board] is to process these claims as ‘zero awards’ under Title 2, California Code of Regulations, sections 649(e), 649.9(a)(5), 649.15 and 649.22.” Pursuant to section 649.22 the Board processes a claim as a “zero award” “where the applicant fails to produce evidence of pecuniary loss.” Processing a claim as a zero award does not constitute a denial of a claim. Instead, the Board makes an “initial determination of eligibility without reference to specific pecuniary loss.” {Ibid) “In the Board’s view, the claims of indigent patiepts treated at county hospitals do not constitute ‘pecuniary losses’ to the patients within the meaning of Government Code section 13959, since the County has an obligation under Welfare and Institutions code section 17000 et seq. to provide this medical care to indigent patients. Therefore, in the Board’s view, these applications are ‘without verified pecuniary loss’ within the meaning of California Code of Regulations, title 2, section 649.15. Alternatively, the Board views County CMSP funding as ‘collateral benefits’ as defined in California Code of Regulations, title 2, section 649(j). Accordingly, the Board believes that, under the provisions of section 649.17, indigent patients’ claims must be ‘zero awarded’ until such time as the County makes a ‘share of cost’ determination under its CMSP guidelines. The County has records of 185 *1102 claimants with claims totalling $903,941.21 whose claims have been zero awarded in this way.” 2

“In the case of private hospitals, the Board’s policy is to pay the treating hospital directly on approved Victims of Crime Program applications,” unless the county is employing the hospital as a means of meeting its Welfare and Institutions Code section 17000 obligation to provide medical services to indigent patients.

The trial court found, based on these undisputed facts, that “notwithstanding Welfare and Institutions Code section 17000, there is an obligation of the indigent patient to pay the County for medical services rendered which arises when the services are rendered. The obligation becomes due upon the subsequent acquisition of property by the patient. Welfare and Institutions Code section 17403 is clearly based on a preexisting debt which is the basis for the obligation to satisfy the debt from after-acquired property. For this reason, the court concludes that bills for medical treatment rendered to indigent patients at county hospitals constitute pecuniary losses to these patients within the meaning of Government Code section 13959.”

Based on these findings, the court granted the County’s motion for summary judgment and entered judgment for the County providing declaratory and injunctive relief.

I.

Standing

By this action the County is seeking to compel the Board to pay the claims of indigent crime victims for restitution equal to the cost of medical services *1103 provided by the county hospital pursuant to Welfare and Institutions Code section 17000. It is undisputed that none of the crime victims whose claims have been “zero awarded” are parties to this action, The threshold question in this case, therefore, is whether the County of Alameda, or Don Perata in his capacity as a county taxpayer, has standing to assert the claims of these crime victims for compensation.

California Code of Civil Procedure section 367 provides that “[e]very action must be prosecuted in the name of the real party in interest.” (2a) The real party in interest is one “having an actual and substantial interest in the subject matter of the action and who would be benefitted or injured by the judgment in the action.” (Friendly Village Community Assn., Inc. v. Silva & Hill Constr. Co.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Steinbruner v. Soquel Creek Water District CA6
California Court of Appeal, 2025
Karpinski v. Smitty's Bar, Inc.
246 Cal. App. 4th 456 (California Court of Appeal, 2016)
City of Oakland v. Oakland Police & Fire
California Court of Appeal, 2014
City of Industry v. City of Fillmore
198 Cal. App. 4th 191 (California Court of Appeal, 2011)
Fuchino v. Edwards-Buckley
196 Cal. App. 4th 1128 (California Court of Appeal, 2011)
In Re Corrine W.
45 Cal. 4th 522 (California Supreme Court, 2009)
Contra Costa County Bureau of Children & Family Services v. Y.C.
45 Cal. 4th 522 (California Supreme Court, 2009)
Washington Mutual Bank v. Blechman
69 Cal. Rptr. 3d 87 (California Court of Appeal, 2007)
People v. Hove
91 Cal. Rptr. 2d 128 (California Court of Appeal, 1999)
County of San Diego v. State
931 P.2d 312 (California Supreme Court, 1997)
Tailfeather v. Board of Supervisors
48 Cal. App. 4th 1223 (California Court of Appeal, 1996)
Save Our Bay, Inc. v. San Diego Unified Port District
42 Cal. App. 4th 686 (California Court of Appeal, 1996)
Untitled California Attorney General Opinion
California Attorney General Reports, 1995
Gardner v. County of Los Angeles
34 Cal. App. 4th 200 (California Court of Appeal, 1995)
Adams v. Commission on Judicial Performance
882 P.2d 358 (California Supreme Court, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
14 Cal. App. 4th 1096, 18 Cal. Rptr. 2d 487, 93 Daily Journal DAR 4224, 1993 Cal. App. LEXIS 360, Counsel Stack Legal Research, https://law.counselstack.com/opinion/county-of-alameda-v-state-board-of-control-calctapp-1993.