Saint Alphonsus Reg'l Med. Ctr. v. Raney, 413 P.3d 742

Patient was jailed in Ada County on criminal charges and attempted suicide in custody; he was hospitalized at Saint Alphonsus from March 26, 2014, to late May 2014.
The State moved to release Patient on his own recognizance in the pending criminal cases so family could make medical decisions and facilitate treatment; magistrate granted release orders on April 3–4, 2014.
Ada County paid hospital expenses only from March 27 to April 4 (period while Patient remained in custody); Saint Alphonsus sought payment for the entire hospitalization.
Saint Alphonsus sued Ada County for declaratory relief and damages under Idaho statutes governing county responsibility for prisoners’ medical expenses (Idaho Code §§ 20-605, 20-612, 31-3302).
The district court granted Ada County summary judgment, holding county obligation ended upon release from custody; Saint Alphonsus appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether county must pay entire hospitalization when inmate is released from custody to receive medical treatment	1994 amendments to §§ 20-605, 20-612, 31-3302 unambiguously require county to pay full hospitalization at Medicaid rate if release is for medical treatment	County only owes medical costs while person remains in custody; release ends county obligation	Court held county must pay entire hospitalization when release was for receiving medical treatment; vacated district court judgment

Saint Alphonsus Regional Medical Center, Ltd. v. Killeen, [citation="124 Idaho 197, 858 P.2d 736"] (1993) (held county/sheriff responsible for prisoners’ medical expenses but obligation ended after release from custody)
Bannock County v. City of Pocatello, [citation="110 Idaho 292, 715 P.2d 962"] (1986) (statutes §§ 20-604–606 address housing prisoners in another county; §20-612 applies within county)
State v. Dunlap, [citation="155 Idaho 345, 313 P.3d 1"] (2013) (explains objective and principles of statutory interpretation)