BHC Intermountain Hospital, Inc. v. Ada County
150 Idaho 93
| Idaho | 2010Background
- I.C. § 66-327(a) governs who pays costs of commitment and care for involuntarily hospitalized mentally ill patients.
- John Doe, an indigent Ada County resident, incurred $7,023.61 in Intermountain Hospital during February 2008 treatment.
- Magistrate court held Ada County responsible and limited reimbursement to the Medicaid rate under chapter 35, title 31.
- Intermountain appealed, arguing §66-327(a) sets full reimbursement, not the Medicaid rate.
- District court affirmed the magistrate’s ruling applying the Medicaid rate; appeal proceeded after a stay linked to another BHC case.
- Court held that the reimbursement rate is determined by §66-327(a) itself and not limited by chapter 35, title 31.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §66-327(a) set full reimbursement by the responsible party? | Intermountain: full amount owed by patient or county, not Medicaid rate. | Ada County: Medicaid rate governs amount due under chapter 35, title 31. | §66-327(a) controls the rate; not limited by chapter 35, title 31. |
| What is the meaning of the reference to chapter 35, title 31 in §66-327(a)? | Reference guides indigency and county of residence only. | Reference also controls rate payable by county. | Reference relates to indigency and residency, not the reimbursement rate. |
Key Cases Cited
- Gibson v. Ada County, 142 Idaho 746 (2006) (statutory interpretation framework; plain meaning and legislative intent examined)
- State v. Hensley, 187 P.3d 1227 (2008) (statutory interpretation and ambiguity analysis)
- State v. Yzaguirre, 163 P.3d 1183 (2007) (ambiguity requires legislative intent; analyze language and policy)
- In re Daniel W., 183 P.3d 765 (2008) (referencing related statutes; incorporation limits)
