ARMOR CORRECTIONAL HEALTH SERVICES INC. v. BD. OF COUNTY COMM'RS OF OKLA. COUNTY
2017 OK 49
| Okla. | 2017Background
- Armor Correctional Health Services contracted with Oklahoma County to provide inmate medical care (initial term Jan–Jun 2014; extended Jul 2014–Jun 2015).
- County admitted Armor performed the services and that unpaid invoices totaled $3,302,297.04.
- County refused payment citing Art. 10, § 26 (constitutional debt limit) and argued Armor had not proved availability of funds per 62 O.S. §§ 362–363.
- Armor sought summary judgment on its contract claim and submitted budgetary evidence and Treasurer reports to satisfy § 362 proof of available funds.
- Trial court entered summary judgment for Armor; County appealed raising jurisdictional/constitutional defenses.
- The Supreme Court affirmed judgment for Armor but on the basis that the county had appropriated the contract and Armor met § 362 proof requirements; the sheriff’s duty to provide inmate medical care is a constitutionally mandated function supporting payment priority.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether judgment can enter absent proof of available municipal funds under 62 O.S. § 362 | Armor: § 362 proof satisfied by itemized indebtedness, budgets, and Treasurer reports showing funds available | County: Armor failed to prove funds availability as required; § 362 is jurisdictional | Held: Armor presented prima facie § 362 proof; judgment proper because County had appropriated the contract and funds were shown available |
| Whether the county's obligation is barred by Art. 10, § 26 indebtedness limits | Armor: obligation arises from constitutionally mandated sheriff function (care of prisoners) and is entitled to payment priority | County: Art. 10, § 26 forbids incurring indebtedness beyond revenues without voter approval; thus payment barred | Held: Court did not need to invoke Smartt exception; nevertheless, inmate medical care is a constitutionally mandated function and the contract was fully appropriated, so § 26 did not prevent judgment |
| Effect of sheriff special revenue shortfall on County's liability | Armor: County could transfer or use general funds; failure of a special fund does not negate availability shown under § 362 | County: Sheriff’s fund revenue failure precluded payment and justified withholding | Held: Special fund shortfall insufficient; County had funds on hand and could have made supplemental/transfers; withholding was not a defense |
| Whether §§ 362–363 are jurisdictional and require strict compliance | Armor: complied with statutory proof; court may enter judgment | County: absence or insufficiency of § 362 proof renders judgment void | Held: §§ 362–363 are jurisdictional, but Armor met their requirements so judgment stands |
Key Cases Cited
- Smartt v. Board of County Comm'rs of Craig County, 169 P. 1101 (Okla. 1917) (constitutional duties of sheriff; debts for necessary discharge of those duties may be outside Art. 10 § 26 limits)
- Protest of Kansas City Southern Ry. Co., 11 P.2d 500 (Okla. 1932) (supplemental appropriations and priority treatment where appropriations are insufficient)
- Baylis v. City of Tulsa, 780 P.2d 686 (Okla. 1989) (§§ 362–363 function as jurisdictional predicates governing municipal expenditures under Art. 10 § 26)
- City of Del City v. Fraternal Order of Police, Lodge No. 114, 869 P.2d 309 (Okla. 1993) (discussion of narrow construction of Smartt exception to avoid swallowing the constitutional rule)
- Oklahoma City v. Green Constr. Co., 84 P.2d 623 (Okla. 1938) (requirement that party seeking judgment against municipality provide § 362 proof)
- HCA Health Servs. of Okla., Inc. v. Whetsel, 173 P.3d 1203 (Okla. 2007) (establishing county duty to provide medical care to prisoners)