951 N.W.2d 544
S.D.2020Background
- Avera Sacred Heart Hospital sued Yankton County seeking reimbursement for medical care of 23 indigent patients held on emergency mental-health (SDCL ch. 27A-10) holds at a regional facility while pre-commitment medical treatment or clearance was pending.
- The holds lasted from one to twelve days; all patients were uninsured and medically indigent; Hospital billed the County but County refused, arguing statutory procedures for indigent reimbursement (SDCL ch. 28-13) were not followed.
- The circuit court initially granted summary judgment to the Hospital on due-process grounds, then granted the County’s motion to reconsider and issued a final judgment for the County.
- The Supreme Court reviewed whether SDCL ch. 27A-10 imposes county liability for pre-commitment medical expenses or whether reimbursement must proceed under SDCL ch. 28-13 procedures.
- The Court held SDCL ch. 27A-10 does not expressly require counties to pay pre-commitment medical care; SDCL ch. 28-13 sets the exclusive statutory reimbursement procedure and the Hospital failed to use it.
- The Court rejected Hospital’s quantum meruit claim and found the trial court properly reconsidered its memorandum decision before entering final judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court erred by granting County summary judgment | 27A-10’s “no lien” and detainment-cost language makes County liable for pre-commitment medical costs | SDCL ch. 28-13 provides the county-reimbursement procedure for indigent care; 27A-10 does not impose county payment | Affirmed: County not liable; Hospital must use SDCL ch. 28-13 procedures and did not do so |
| Whether Hospital may recover in quantum meruit from County | Equitable restitution is appropriate because County had responsibility to provide care for detained mentally ill indigents | No statutory duty to pay outside ch. 28-13; services were provided to indigents and reimbursement is governed by statute | Denied: quantum meruit fails because no obligation outside statutory scheme |
| Whether the court erred in granting motion to reconsider | Trial court delayed final judgment and improperly reconsidered | Memorandum opinions are nonbinding; court may rethink a memorandum and later enter final judgment | Denied: reconsideration of a memorandum was proper and final judgment was timely |
Key Cases Cited
- Doe ex rel. Tarlow v. District of Columbia, 920 F. Supp. 2d 112 (D.D.C. 2013) (discussed substantive-due-process obligations to detainees' medical needs)
- City of Revere v. Massachusetts General Hospital, 463 U.S. 239 (U.S. 1983) (constitutional duty to ensure care does not fix how costs are allocated; allocation is state law)
- Sioux Valley Hospital Ass'n v. Davison Cnty., 298 N.W.2d 85 (S.D. 1980) (county liability for indigent medical care must be found in statute)
- Appeal of Presentation Sisters, Inc., 471 N.W.2d 169 (S.D. 1991) (hospitals may be reimbursed by county if they comply with ch. 28-13 procedures)