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BHC Intermountain Hospital, Inc. v. Ada County
150 Idaho 93
| Idaho | 2010
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Background

  • 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)
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Case Details

Case Name: BHC Intermountain Hospital, Inc. v. Ada County
Court Name: Idaho Supreme Court
Date Published: Dec 8, 2010
Citation: 150 Idaho 93
Docket Number: 37352
Court Abbreviation: Idaho