St. Al's RMC v. Ada Co Sheriff & Bd of Comm

CourtIdaho Supreme Court
DecidedMarch 2, 2018
Docket45016
StatusPublished

This text of St. Al's RMC v. Ada Co Sheriff & Bd of Comm (St. Al's RMC v. Ada Co Sheriff & Bd of Comm) 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
St. Al's RMC v. Ada Co Sheriff & Bd of Comm, (Idaho 2018).

Opinion

IN THE SUPREME COURT OF THE STATE OF IDAHO

DOCKET NO. 45016

SAINT ALPHONSUS REGIONAL ) MEDICAL CENTER, ) ) ) Plaintiff-Appellant, ) Boise, January 2018 Term v. ) ) 2018 Opinion No. 14 ) ADA COUNTY SHERIFF GARY RANEY, in ) Filed: March 2, 2018 his Official Capacity; ADA COUNTY, and ) the BOARD OF ADA COUNTY ) Karel A. Lehrman, Clerk COMMISSIONERS, ) ) ) Defendants-Respondents. ) _______________________________________ )

Appeal from the District Court of the Fourth Judicial District of the State of Idaho, Ada County. Hon. Richard D. Greenwood, District Judge.

The district court’s judgment is vacated and remanded for further proceedings.

Duke Scanlan & Hall, PLLC, Boise, for appellant. Bryan A. Nickels argued.

Jan M. Bennetts, Ada County Prosecutor, Boise, for respondent. Joseph D. Mallet argued. _____________________

BRODY, Justice. Saint Alphonsus Regional Medical Center, Inc. (“Saint Alphonsus”) appeals summary judgment entered in favor of Ada County Sheriff, Gary Raney, in his official capacity; Ada County; and the Board of Ada County Commissioners, (collectively, “Ada County”). The district court ruled as a matter of law that Ada County was not obligated to pay for an inmate’s (“Patient”) entire hospitalization where the State sought a release from custody during the hospitalization so the inmate could receive medical treatment. The district court ruled that Ada County’s obligation to pay for the hospitalization stopped once a release order was entered. We hold the district court erred in its interpretation of Idaho Code sections 20-605 and 20-612 and

1 vacate the judgment entered in favor of Ada County. We remand for further proceedings consistent with this opinion. I. FACTUAL AND PROCEDURAL BACKGROUND In January 2014, Patient was charged with domestic battery or assault in the presence of a child. He was incarcerated at the Ada County jail after he was unable to post bond (the “First Criminal Case”). On March 26, 2014, while still in jail, Patient was charged with three counts of sexual abuse of a minor under sixteen years of age (the “Second Criminal Case”). Patient’s arraignment on the Second Criminal Case was scheduled for the next day. Prior to his arraignment, Patient attempted suicide by hanging himself. He was transported to Saint Alphonsus for medical treatment and remained there for about two months until he was discharged from the hospital at the end of May 2014. A pretrial conference in the First Criminal Case occurred on April 3, 2014. The prosecuting attorney and defense counsel met with the magistrate judge in chambers where the judge was advised that Patient had been charged in the Second Criminal Case and was in the hospital after attempting suicide in the jail. The minutes from that meeting indicate that the judge was advised that Patient was likely to survive, but his long term health was in question. The State moved to release Patient on his own recognizance in the First Criminal Case only. The magistrate judge granted the motion and entered an order of release. The next day, the State filed an ex parte motion to release Patient on his own recognizance in the Second Criminal Case. The State’s motion advised the court that it wanted to release Patient so that his family could make necessary medical decisions and facilitate a possible transfer to another medical facility (which apparently never occurred). The State also indicated that it intended to seek immediate reinstatement of the bond if Patient’s condition improved to the point he could be released from the hospital. The magistrate court entered an order releasing Patient on his own recognizance in the Second Criminal Case on April 4, 2014. Ada County paid the medical expenses associated with Patient’s hospitalization from March 27, 2014 to April 4, 2014 when Patient was released from the State’s custody in both criminal cases. Saint Alphonsus filed a verified complaint for declaratory judgment and damages against Ada County, claiming that, pursuant to Idaho Code sections 20-604 and 20-605, Ada County improperly denied Saint Alphonsus’ claim for payment for the entire hospitalization.

2 Both parties filed cross motions for summary judgment. Ada County argued that it was obligated to pay for medical expenses for an inmate only while the inmate was in custody. Saint Alphonsus argued that in 1994 the Legislature amended Idaho Code sections 20-605, 20-612 and 31-3302 to provide that a release from custody for purposes of receiving medical treatment will not relieve a county from its responsibility to pay for Patient’s hospitalization. The district court granted Ada County’s motion and entered a judgment dismissing Saint Alphonsus’ claims with prejudice. Saint Alphonsus timely appealed. II. STANDARD OF REVIEW This Court applies the same standard of review that was used by the trial court in ruling on a motion for summary judgment. Quemada v. Arizmendez, 153 Idaho 609, 612, 288 P.3d 826, 829 (2012) (quoting Vreeken v. Lockwood Eng’g, B. V., 148 Idaho 89, 101, 218 P.3d 1150, 1162 (2009)). Summary judgment is proper “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” I.R.C.P. 56(a). “[T]his Court construes disputed facts, and all reasonable inferences that can be drawn from the record, in favor of the non-moving party.” Grabicki v. City of Lewiston, 154 Idaho 686, 690, 302 P.3d 26, 30 (2013) (internal citation omitted). “The moving party is entitled to judgment when the nonmoving party fails to make a showing sufficient to establish the existence of an element essential to that party’s case on which that party will bear the burden of proof at trial.” Badell v. Beeks, 115 Idaho 101, 102, 765 P.2d 126, 127 (1988) (citing Celotex v. Catrett, 477 U.S. 317 (1986)). III. ANALYSIS A. The district court erred when it held that Idaho Code sections 20-605 and 20-612 do not obligate Ada County to pay for Patient’s entire hospitalization where he was released from custody for the purpose of receiving medical treatment. We are asked once again to determine which of these parties bears responsibility for an inmate’s medical expenses. This Court first addressed this issue in Saint Alphonsus Regional Medical Center, Ltd., v. Killeen, 124 Idaho 197, 858 P.2d 736 (1993). In Killeen, an Ada County jail inmate was taken to Saint Alphonsus to receive treatment for chest pain. Id. at 197, 858 P.2d at 736. While she was in the hospital, she was released from the sheriff’s custody on her own recognizance. Id. Saint Alphonsus filed suit against Ada County seeking payment for the inmate’s hospitalization. Id. at 198, 858 P.2d at 737.

3 The magistrate court in Killeen determined that Ada County had an obligation to pay the inmate’s medical expenses, but limited the obligation to those expenses incurred prior to the inmate’s release from custody. Id. Both parties appealed the magistrate court’s decision, and the case eventually made its way to this Court. Ada County took the position that Saint Alphonsus’ claim for payment was governed by Idaho’s medical indigency statutes (Idaho Code section 31- 3501 et seq.) and that it had no responsibility for payment as part of the inmate’s incarceration. Id.

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St. Al's RMC v. Ada Co Sheriff & Bd of Comm, Counsel Stack Legal Research, https://law.counselstack.com/opinion/st-als-rmc-v-ada-co-sheriff-bd-of-comm-idaho-2018.