Opinion No. 14
from the District Court of the Fourth Judicial District of
the State of Idaho, Ada County. Hon. Richard D. Greenwood,
district court's judgment is vacated and
remanded for further proceedings.
Scanlan & Hall, PLLC, Boise, for appellant. Bryan A.
Bennetts, Ada County Prosecutor, Boise, for respondent.
Joseph D. Mallet argued.
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 vacate the judgment entered in
favor of Ada County. We remand for further proceedings
consistent with this opinion.
Factual and Procedural Background
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
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.
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,
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.
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.