Sioux Valley Hospital Ass'n v. Lake County

533 N.W.2d 161, 1995 S.D. LEXIS 66, 1995 WL 355162
CourtSouth Dakota Supreme Court
DecidedJune 14, 1995
DocketNo. 18918
StatusPublished

This text of 533 N.W.2d 161 (Sioux Valley Hospital Ass'n v. Lake 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
Sioux Valley Hospital Ass'n v. Lake County, 533 N.W.2d 161, 1995 S.D. LEXIS 66, 1995 WL 355162 (S.D. 1995).

Opinion

SABERS, Justice.

Beman was admitted to Hospital for emergency care. Hospital sought payment for medical costs from County. County refused, claiming he was not “indigent” under its guidelines. The trial court found he was “indigent” and ordered County to pay medical costs. County appeals and we affirm.

FACTS

David Beman (Beman), a resident of Madison, Lake County, South Dakota, was admitted to Sioux Valley Hospital (Hospital) on October 25, 1992 for emergency care. On October 26, 1992, Hospital sent notice of hospitalization to Lake County. Between October 25 and November 5, 1992, Hospital furnished Beman medical services of $5,159.69.

At the time of hospitalization and when the bill was due, Beman and his wife Ruth Be-man had approximately $4,500 in assets and $55,000 to $60,000 in debts. The trial court found Beman and his wife had income of approximately $1,800.00 per month and “reasonable monthly expenses in the amount of approximately $1,900.00.”

Lake County (County) had established guidelines to determine “indigency” under SDCL 28-13. The Beman household consists of Beman, his wife, and her three children. For a household of five, the County’s maximum income for welfare eligibility was $1,025.00 per month. County determined he was not indigent because the Beman household income exceeded this level. County refused to pay Beman’s hospital bill.

Beman filed a Chapter 7 bankruptcy petition on June 14, 1994, ten days before trial. County also claims its obligation is extinguished by Beman’s bankruptcy filing because once his debts were discharged, he could pay the bill.

Hospital sued, claiming Beman was indigent and County’s guidelines do not conform to state law. The trial court found the Be-mans did not have sufficient funds to meet medical debts. The court concluded Beman was “indigent” and Hospital was entitled to judgment in the amount of $5,159.69, plus [163]*163pre-judgment interest and costs. County appeals.

1. Whether Beman was “indigent?”

“Every county has a duty to support indigents residing within its boundaries.” Appeal of Presentation Sisters, Inc., 471 N.W.2d 169, 174 (S.D.1991) (citing SDCL 28-13-1). SDCL 28-13-1.1 provides in part:

[A]n indigent or poor person is any person who does not have sufficient money, credit or property to furnish support or does not have anyone able to support him to whom he is entitled to look for support or is unable to work because of illness or inju-ry_ [E]ach county shall establish reasonable eligibility standards for county poor relief. However, such standards shall be consistent with relevant federal statutes, case law and the provisions of this section and [SDCL] 28-13-1.2.

Id.

Medical indigency is to be determined in light of the facts that exist upon hospital admission and at the time the bill is due. Sioux Valley Hosp. Ass’n v. Davison County, 319 N.W.2d 490, 492 (S.D.1982); Sioux Valley Hosp. Ass’n v. Mies, 422 N.W.2d 414, 417 (S.D.1988). The determination that an individual is indigent is a question of fact to be determined by the trial court. Davison County, 319 N.W.2d at 491; Mies, 422 N.W.2d at 417. Findings of fact will not be disturbed unless they are clearly erroneous. Cordell v. Codington County, 526 N.W.2d 115, 116 (S.D.1994).

“In South Dakota, counties have a specific duty to provide hospitalization, medical care, and treatment for poor persons.” Appeal of Presentation Sisters, Inc., 471 N.W.2d at 174 (citations omitted). Hospitals may be paid for medical expenses by the indigent’s county of residence if the hospital complies with procedural requirements. Id. (citation omitted). It is undisputed Hospital complied with procedural requirements on notice. County did not inform Hospital that it was not going to pay for the hospitalization, nor did it seek alternative treatment. Sioux Valley Hosp. Ass’n. v. Tripp County, 404 N.W.2d 519, 523 (S.D.1987) (Sabers, J. and Wuest, C.J. dissenting). Therefore, County is liable to Hospital if Beman was indigent.1

County claims Beman is not eligible for relief as an “indigent” because his income exceeded County’s guidelines for indigency. County claims Ruth Beman is employed and will have a higher paying job once she graduates with a degree in medical records. As we noted in Sioux Valley Hosp. Ass’n v. Jones County, 309 N.W.2d 835, 837 (S.D.1981), “emergency assistance eligibility was not based on a complete lack of resources, but also applied to ‘those persons who do not have the present or future hope of resources sufficient to pay for all the medical and hospital services required in emergency instances.’ ” (quoting St. Patrick Hosp. v. Powell County, 156 Mont. 153, 477 P.2d 340, 343 (1970)). See Mies, 422 N.W.2d at 417.

Hospital notified County according to SDCL 28-13. The court found Beman could not pay the hospital bill. The court found Beman “indigent” according to SDCL 28-13-l.l.2 County has not shown this finding to be erroneous.

2. Whether Beman’s bankruptcy extinguishes County’s obligation to pay for his hospitalization?

Beman filed a Chapter 7 bankruptcy petition ten days before trial. In his [164]*164schedules, he listed several medical debts. County claims once these other debts are discharged, Beman would not be eligible for County assistance because of his decreased debt load. County claims the court erred by not considering Beman’s bankruptcy discharge in determining his indigency.

According to 11 U.S.C. § 524(e):

Except as provided ... discharge of a debt of the debtor does not affect the liability of any other entity on, or the property of any other entity for, such debt.

A discharge in bankruptcy frees the bankrupt from personal liability but does not extinguish the debt. U.S. v. Midwest Livestock Producers Coop., 493 F.Supp. 1001, 1002 (E.D.Wis.1980) (citations omitted). A bankruptcy creditor may bring an action against a surety or guardian or other third person despite the bankrupt’s discharge. See R.I.D.C. Indus. Dev. Fund v. Snyder,

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

Related

Saint Patrick Hospital v. Powell County
477 P.2d 340 (Montana Supreme Court, 1970)
Carpenter v. Twin Falls County
691 P.2d 1190 (Idaho Supreme Court, 1984)
Claussen v. Brookings County (In Re Claussen)
118 B.R. 1009 (D. South Dakota, 1990)
United States v. Midwest Livestock Producers, Cooperative
493 F. Supp. 1001 (E.D. Wisconsin, 1980)
Cordell v. Codington County
526 N.W.2d 115 (South Dakota Supreme Court, 1994)
In Re the Appeal of Presentation Sisters, Inc.
471 N.W.2d 169 (South Dakota Supreme Court, 1991)
Sioux Valley Hospital Ass'n v. Mies
422 N.W.2d 414 (South Dakota Supreme Court, 1988)
Sioux Valley Hospital Ass'n v. Jones County
309 N.W.2d 835 (South Dakota Supreme Court, 1981)
Sioux Valley Hospital Ass'n v. Tripp County
404 N.W.2d 519 (South Dakota Supreme Court, 1987)
Sioux Valley Hospital Ass'n v. Davison County
319 N.W.2d 490 (South Dakota Supreme Court, 1982)
Snyder v. R. I. D. C. Industrial Development Fund
429 U.S. 1095 (Supreme Court, 1977)
McGraw v. Berger
429 U.S. 1095 (Supreme Court, 1977)

Cite This Page — Counsel Stack

Bluebook (online)
533 N.W.2d 161, 1995 S.D. LEXIS 66, 1995 WL 355162, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sioux-valley-hospital-assn-v-lake-county-sd-1995.