St. Alphonsus Regional Medical Center, Ltd. v. Killeen

858 P.2d 760, 124 Idaho 221, 1992 Ida. App. LEXIS 83
CourtIdaho Court of Appeals
DecidedApril 6, 1992
DocketNo. 19311
StatusPublished
Cited by1 cases

This text of 858 P.2d 760 (St. Alphonsus Regional Medical Center, Ltd. v. Killeen) is published on Counsel Stack Legal Research, covering Idaho Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
St. Alphonsus Regional Medical Center, Ltd. v. Killeen, 858 P.2d 760, 124 Idaho 221, 1992 Ida. App. LEXIS 83 (Idaho Ct. App. 1992).

Opinion

WALTERS, Chief Judge.

This case concerns the recovery of costs incurred by a private hospital in providing emergency medical care to an indigent pretrial detainee in the custody of a county sheriff. A magistrate determined that the county was liable for the costs incurred before the detainee was released from county custody, although the release occurred while the detainee was still hospitalized. Accordingly, the magistrate granted judgment to the hospital for part of its claim. On appeal, the district court af[222]*222firmed. The hospital has appealed from the district court’s order, arguing that it is entitled to recover all of its costs, not just the portion incurred before the detainee was released from custody. The sheriff and the county have cross-appealed, contending that neither the sheriff nor the county should be liable for any of the hospital’s claim. We hold that the hospital’s claim in this case is controlled by Idaho’s statutory provisions for the payment of services rendered to medically indigent patients and we reverse the magistrate’s judgment.

Facts and Procedural Background

Mrs. Marjorie Edmonds was arrested, pursuant to a warrant, for writing a bad check in Ada County and then failing to appear at her preliminary hearing. The arrest occurred in Canyon County, Mrs. Edmonds’ county of residence. She was then delivered to Ada County authorities who booked her into the Ada County jail on Friday, September 23, 1988.

Mrs. Edmonds had a history of heart problems. Early Sunday morning, September 25, she suffered chest pains and shortness of breath. Paramedics were called and, at approximately 4:08 a.m., transported her to the nearest hospital, St. Alphon-sus Regional Medical Center (St. Alphon-sus). An Ada County Deputy Sheriff followed. No prior arrangements existed between the hospital, the sheriff or Ada County for the treatment of prisoners. No one from Ada County signed an admissions form at the hospital and there is no indication that the sheriffs office chose St. Al-phonsus.

Upon examination, a doctor at St. Al-phonsus determined, at 5:38 a.m., that Mrs. Edmonds should be admitted for observation. After learning this, the sheriff’s office contacted a deputy prosecuting attorney, who in turn spoke with an Ada County magistrate and persuaded the magistrate to enter a hand-written order releasing Mrs. Edmonds on her own recognizance. Mrs. Edmonds was released from the sheriff’s custody at 7:45 a.m., while still a patient at the hospital. The record does not indicate how or when she or St. Alphonsus was notified of that release. Ultimately, she was discharged from the hospital’s care on Tuesday, September 27, 1988. The total bill for her treatment was $1,852.22, of which $1,035.40 was incurred before her release from county custody.

St. Alphonsus sought payment from the Ada County Sheriff and Ada County for the total cost of Mrs. Edmonds’ treatment. At the same time, the hospital asserted that Mrs. Edmonds was medically indigent and submitted claims to both Ada and Canyon counties under state statutes covering payment for medical services for indigents. Both claims were denied.1 Specifically, Canyon County denied the claim on the basis that Ada County or its sheriff should pay. When the sheriff refused, St. Alphon-sus sued the Ada County Sheriff, the Ada County Board of Commissioners, and Ada County (collectively “Ada County”). Ada County denied liability, asserting that Canyon County, Mrs. Edmonds’ county of residence, was responsible for the costs. Even though it has a direct interest in the outcome, Canyon County has not been made a party to the lawsuit.

Both St. Alphonsus and Ada County moved for summary judgment. The hospital argued that Ada County was responsible for the entire amount of Mrs. Edmonds’ bill. Ada County, on the other hand, argued that Canyon County, Mrs. Edmonds’ county of residence, should pay. The magistrate granted the motion in favor of St. Alphonsus and awarded $1,035.40 for the services performed before Mrs. Edmonds’ release from custody, plus prejudgment interest from October 9, 1989, at a rate of twelve per cent, and attorney fees. The magistrate determined that Ada County had a statutory duty to provide treatment and also to pay for it; and that the sheriff had entered into an implied agreement with St. Alphonsus to pay for Mrs. Edmonds’ treatment. The court expressly found, however, that there was no basis for coun[223]*223ty liability after Mrs. Edmonds was released on her own recognizance.

Both parties appealed to the district court, which affirmed the magistrate’s decision. However, the court held that Ada County had only a statutory duty to pay for the medical services provided to an indigent pretrial detainee. The court limited recovery to the portion of Mrs. Ed-monds’ bill attributed to her treatment before her release from custody. It found no liability for the remainder of the bill, finding no implied contract, quasi-contract, or quasi-estoppel basis for total recovery. The court also affirmed the award of prejudgment interest and attorney fees. Both parties appeal to this Court, asserting the same positions they took below.

Question Presented

Is a county sheriff responsible for payment of all or part of the emergency medical services provided by a private hospital to a non-resident, indigent, pretrial detainee who suffers an illness while in the sheriff’s custody?

Standard of Review

The facts in this case are uncontroverted. The issue to be resolved involves the disputed application of state statutes. The construction and application of legislative enactments present pure questions of law over which we exercise free review. Standards of Appellate Review in State and Federal Courts, IDAHO APPELLATE HANDBOOK § 3.2.1 (Idaho Law Foundation, Inc. 2d ed. 1989).

Duty to Provide Care

Initially, we point out that the dispute is solely over who will pay for the costs of Mrs. Edmonds’ medical services, and concerns only state law. The eighth amendment to the United States Constitution, applied to the states through the Fourteenth Amendment, mandates that injured persons in custody receive necessary medical care. City of Revere v. Massachusetts General Hospital, 463 U.S. 239, 103 S.Ct. 2979, 77 L.Ed.2d 605 (1983). However:

the Constitution does not dictate how the cost of that care should be allocated as between the [governmental] entity and the provider of the care. That is a matter of state law.
If, of course, the governmental entity can obtain medical care needed for a detainee only by paying for it, then it must pay. There are, however, other means by which the entity could meet its obligation. Many hospitals are subject to federal or state laws that require them to provide care to indigents. [Citations omitted.]

Revere, 463 U.S. at 245, 103 S.Ct. at 2983. This language implies that a governmental entity such as Ada County may not be responsible for the costs of medical care to indigent detainees if the Idaho statutes governing payment for medical services provided to indigents apply. These statutes can only be analyzed in conjunction with our statutes defining the responsibilities of the county sheriff. Unfortunately, there is a void when the two sets of statutes are viewed together.

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Related

Brown v. County Commissioners
658 A.2d 255 (Court of Appeals of Maryland, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
858 P.2d 760, 124 Idaho 221, 1992 Ida. App. LEXIS 83, Counsel Stack Legal Research, https://law.counselstack.com/opinion/st-alphonsus-regional-medical-center-ltd-v-killeen-idahoctapp-1992.