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Saint Alphonsus Regional Medical Center v. Raney

Supreme Court of Idaho

March 2, 2018

SAINT ALPHONSUS REGIONAL MEDICAL CENTER, Plaintiff-Appellant,
v.
ADA COUNTY SHERIFF GARY RANEY, in his Official Capacity; ADA COUNTY, and the BOARD OF ADA COUNTY COMMISSIONERS, Defendants-Respondents.

         2018 Opinion No. 14

         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 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.

          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. ...


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