ARMOR CORRECTIONAL HEALTH SERVICES INC. v. BD. OF COUNTY COMM'RS OF OKLA. COUNTY
2017 Okla. LEXIS 51
| Okla. | 2017Background
- Armor provided medical services to inmates at the Oklahoma County Jail under a contract (Jan 1, 2014–June 30, 2014) and an extension (July 1, 2014–June 30, 2015).
- County admitted Armor's invoices totaling $3,302,297.04 were unpaid despite valid work performed.
- County argued Armor's claim is not subject to 62 O.S. 2011 §§ 362-363 and that Article 10, §26 requires proof of fund availability.
- Trial court granted summary judgment to Armor, finding prima facie proof of funds; County appealed for de novo review.
- This Court affirms the judgment for Armor, holding that §§ 362-363 apply to contract claims against a county where funds were appropriated and available, and that constitutionally-mandated government functions may justify obligations without violating §26.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Armor’s claim is governed by Article 10, §26 or §§362-363. | Armor.maintenance of funds suffices; constitutionally mandated function. | County. §26 controls indebtedness; funds proof required. | Armor contract claim falls under §§362-363; funds proven. |
| Whether Armor provided proof of availability of funds under §362. | Armor provided invoices with budget and fund availability. | County lacked undisputed funds due to revenue failure. | Armor met §362 requirements; funds were available at time of invoicing. |
| Whether the County’s funds were encumbered or available despite revenue failure. | Funds were available; no encumbrance shown. | Sheriff’s budget revenue failed; funds not available. | Funds were available; County improperly withheld payment. |
| Whether the debt arises from a constitutionally mandated governmental function and thus is exempt from §26. | Costs for keeping prisoners are constitutionally mandated. | Smartt exception should apply only narrowly. | No need to invoke Smartt; duty to provide medical care falls under constitutionally mandated functions. |
| Whether §362 is a jurisdictional predicate requiring proof before judgment against a county. | Armor provided §362(1)-(3) materials; proper proof. | County questioned legality of indebtedness. | §362 requirements satisfied; judgment appropriate. |
Key Cases Cited
- Smartt v. Board of County Commissioners of Craig County, 169 P. 1101 (Okla. 1917) (constitutionally mandated functions exempt from debt limits; narrowly construed)
- Protest of Kansas City Southern Ry. Co., 11 P.2d 500 (Okla. 1932) (support for fully appropriated constitutionally mandated obligations)
- Baylis v. City of Tulsa, 780 P.2d 686 (Okla. 1989) (debts for constitutionally mandated functions not subject to §26; jurisdictional limits)
- City of Del City v. Fraternal Order of Police, Lodge No. 114, 869 P.2d 309 (Okla. 1993) (reaffirmed scope of indebtedness and Smartt exception context)
- City of Del City v. Fraternal Order of Police, Lodge No. 114, 869 P.2d 309 (Okla. 1993) (explained cash-basis and priority in budgeting for constitutionally mandated functions)