Sacred Heart Health Services v. Yankton County

951 N.W.2d 544, 2020 S.D. 64
CourtSouth Dakota Supreme Court
DecidedNovember 18, 2020
Docket29153
StatusPublished
Cited by5 cases

This text of 951 N.W.2d 544 (Sacred Heart Health Services v. Yankton County) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sacred Heart Health Services v. Yankton County, 951 N.W.2d 544, 2020 S.D. 64 (S.D. 2020).

Opinion

#29153-a-DG 2020 S.D. 64

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

SACRED HEART HEALTH SERVICES, INC., dba AVERA SACRED HEART HOSPITAL, Plaintiff and Appellant,

v.

YANKTON COUNTY, SOUTH DAKOTA, Defendant and Appellee.

APPEAL FROM THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT YANKTON COUNTY, SOUTH DAKOTA

THE HONORABLE DAVID KNOFF Judge

ROBERT R. NELSON Sioux Falls, South Dakota Attorney for plaintiff and appellant.

DOUGLAS M. DEIBERT of Cadwell, Sanford, Deibert & Garry, LLP Sioux Falls, South Dakota Attorneys for defendant and appellee.

CONSIDERED ON BRIEFS AUGUST 24, 2020 OPINION FILED 11/18/20 #29153

GILBERTSON, Chief Justice

[¶1.] Sacred Heart Health Services, Inc., d/b/a Avera Sacred Heart Hospital

(Hospital), filed a declaratory judgment action against Yankton County (County)

seeking a declaration of the County’s liability and reimbursement for charges for

the medical care and treatment of patients subject to an emergency hold, under

SDCL chapter 27A-10. The parties filed cross-motions for summary judgment. The

circuit court entered a memorandum decision in favor of the Hospital. The County

objected and filed a motion to reconsider. After a second hearing on the motions for

summary judgment, the circuit court issued a second memorandum decision in

favor of the County and entered a corresponding order and judgment. The Hospital

appeals. We affirm.

Facts and Procedural History

[¶2.] In February 2016, the Hospital filed a declaratory judgment action

against the County seeking a declaration of the County’s liability and seeking

reimbursement for the hospitalization and medical treatment provided to patients,

who were subject to an emergency mental illness hold, under SDCL chapter 27A-10.

[¶3.] Under SDCL chapter 27A-10, a person believed to be severely mentally

ill and in need of immediate intervention, may be placed on a 24-hour emergency

hold to protect the person or others from physical harm. SDCL 27A-10-19. A

qualified mental health professional (QMHP) initiates the hold process and submits

a petition for emergency commitment to the chair of a county’s board of mental

illness (Chair). Id. The patient then undergoes an evaluation, which the Chair uses

to determine if the hold should continue. SDCL 27A-10-16. The evaluation is done

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by a QMHP at an appropriate regional facility. 1 Id. After the evaluation, the

QMHP sends the findings to the Chair. SDCL 27A-10-6. The Chair then

determines whether the patient meets the criteria for an involuntary commitment

under SDCL 27A-1-2. If not, SDCL 27A-10-7 requires the person to be released.

But if the individual meets the criteria, the Chair may order a continued hold at a

regional facility pending the hearing required under SDCL 27A-10-8 before an order

of involuntary commitment may be entered. While SDCL 27A-10-7 authorizes the

interim hold to be at the South Dakota Human Services Center (HSC), the South

Dakota Department of Social Services (DSS) has promulgated Guidelines for

Medical Screening (Guidelines) as part of HSC’s admission process to ensure a

patient is medically cleared for transfer to HSC prior to admission. Therefore,

patients who are not medically cleared for HSC are held instead at the regional

facility in the interim.

[¶4.] If the Chair determines the person should be held, the person remains

at the regional facility for up to five days (or up to seven days if there are weekends

and holidays within this time period) during which time the person is entitled to an

involuntary commitment hearing. SDCL 27A-10-8. After the hearing, the person is

either released or committed and transferred to HSC once medically cleared.

[¶5.] In this matter, the twenty-three disputed claims involve the medical

care provided to patients admitted and held under this process while their

commitment hearings or admissions to HSC were pending. The patients’ holds

1. The parties stipulate that the Hospital is an appropriate regional facility under SDCL 27A-1-1(2).

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ranged from a one-day period to a twelve-day period. 2 None of the patients

qualified for an interim hold at HSC prior to a commitment. All the patients

received necessary medical treatment before their commitment hearings

commenced. And all twenty-three patients lacked health insurance and were

indigent.

[¶6.] Prior to this action, in July 2015, the Hospital and the County

attempted to settle all unpaid claims. Originally, the unpaid claims included

eighty-four claims for $1,200 or less per claim, totaling $38,268.02, and twenty-

three claims with larger amounts per claim, totaling $129,630.69 at the county cost

rate. At the July 2015 county commission meeting, the County agreed to and paid

the eighty-four smaller claims. The Hospital claims the County also agreed to pay

the twenty-three larger claims by August 31, 2015, and that the Hospital waived

the accrued interest on the eighty-four smaller claims contingent on the County

paying these twenty-three remaining claims. The County disputes this agreement.

The twenty-three larger claims remain unpaid. The County denies liability for the

unpaid claims, alleging the unpaid claims are the responsibility of the Hospital or

the patient.

[¶7.] In May 2018, the parties filed cross-motions for summary judgment.

The circuit court first issued a memorandum decision in February 2019, granting

summary judgment in favor of the Hospital and denying the County’s motion for

summary judgment.

2. After a patient was medically cleared, twenty-one of the patients were transferred to HSC and two of the patients were discharged.

-3- #29153

[¶8.] The circuit court’s first memorandum decision relied on SDCL 27A-10-

5 and Doe ex rel. Tarlow v. District of Columbia, 920 F. Supp. 2d 112 (D.D.C. 2013)

and determined that the County was responsible for the Hospital’s billings. It

based its decision on the belief that the patients were in the State’s custody during

the involuntary hold process and the State was required on substantive due process

grounds to provide for their basic needs, such as health care. While acknowledging

that SDCL chapter 27A-10 does not contain a provision specifically requiring the

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Cite This Page — Counsel Stack

Bluebook (online)
951 N.W.2d 544, 2020 S.D. 64, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sacred-heart-health-services-v-yankton-county-sd-2020.