Saint Alphonsus Regional Medical Center v. Gooding County
159 Idaho 84
| Idaho | 2015Background
- Patient (D.J.W.) admitted to Saint Alphonsus on July 27, 2013 after an MVC and remained hospitalized.
- Hospital submitted a First Party Combined County Medical Assistance Application received by the Department on August 27, 2013.
- Gooding County Clerk denied the application as untimely; the Board of County Commissioners (BOCC) affirmed, counting the date of admission as day one of the 31‑day deadline.
- Hospital appealed to the Gooding County district court, which reversed the BOCC, holding the date of admission is excluded when computing the 31‑day period under Idaho Code § 31‑3505(3).
- Gooding County appealed to the Idaho Supreme Court; the sole legal question was whether the admission date counts as day one for the § 31‑3505(3) filing deadline.
Issues
| Issue | Hospital's Argument | Gooding County's Argument | Held |
|---|---|---|---|
| Whether the date of hospital admission is included as day one in computing the 31‑day filing deadline under I.C. § 31‑3505(3). | § 31‑3505(3) is ambiguous and § 73‑109 governs time computation, so exclude the admission date (first day excluded). | Plain language "within 31 days of the date of admission" includes the admission date as day one; omission of "beginning with" was not intended to change the computation. | Statute ambiguous; apply I.C. § 73‑109 (first day excluded). Admission date is excluded; Hospital’s filing was timely. |
Key Cases Cited
- St. Luke’s Magic Valley Reg’l Med. Ctr., Ltd. v. Bd. of Cnty. Comm’rs of Gooding Cnty., 150 Idaho 484, 248 P.3d 735 (discusses APA review of county commissioners’ indigency decisions)
- Univ. of Utah Hosp. v. Ada Cnty. Bd. of Comm’rs, 143 Idaho 808, 153 P.3d 1154 (legislative intent of medical indigency statutes: provide care and allow hospital compensation)
- Saint Alphonsus Reg’l Med. Ctr., Ltd. v. Canyon Cnty., 120 Idaho 420, 816 P.2d 977 (interpreting similar statutory time language to exclude the first day)
- IHC Hospitals, Inc. v. Teton Cnty., 139 Idaho 188, 75 P.3d 1198 (applies ordinary time computation to deadlines in medical indigency statutes)
- Harris v. Beco Corp., 110 Idaho 28, 713 P.2d 1387 (recognizes general rule: exclude first day, include last when computing statutory time)
- Verska v. Saint Alphonsus Reg’l Med. Ctr., 151 Idaho 889, 265 P.3d 502 (courts may not insert omitted statutory language; legislative intent controls)
- Nebeker v. Piper Aircraft Corp., 113 Idaho 609, 747 P.2d 18 (amendment of statute presumed to reflect changed legislative intent)