440 P.3d 988
Wash.2019Background
- Thurston County operates a county jail and sought reimbursement from nearby cities (Olympia, Lacey, Tumwater, Yelm; Tenino intervened) for medical costs incurred caring for inmates held in the county jail on felony charges.
- The County has no interlocal agreement with those cities allocating inmate medical costs; some cities operate their own jails or contract for pretrial housing.
- County relied on RCW 70.48.130(6), which states the governing unit operating the jail "may obtain reimbursement for the cost of such medical services from the unit of government whose law enforcement officers initiated the charges on which the person is being held in the jail."
- Cities refused payment, arguing municipalities are not liable for health-care expenses for felony inmates held by the county; County sued for declaratory relief. The trial court granted summary judgment for the Cities; County appealed directly to the Supreme Court.
- The Supreme Court reviewed statutory interpretation de novo, considering RCW 70.48.130 in context with the City and County Jails Act, the Interlocal Cooperation Act (RCW 39.34.180), the Court Improvement Act, and related statutes and rules governing who initiates charges.
- The Court concluded RCW 70.48.130(6) should be read narrowly (applicable to costs when one government holds inmates on misdemeanor/gross misdemeanor charges initiated under citation procedures), and a county may not shift felony inmate medical costs to cities simply because a city officer made the arrest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RCW 70.48.130(6) allows a county to seek reimbursement from a city for medical costs of inmates held on felony charges where a city officer made the arrest | County: statute’s phrase "unit whose law enforcement officers initiated the charges" plainly means the employer of the arresting officer and permits cost-shifting to the city | Cities: counties bear responsibility for felony prosecutions and related incarceration costs; statute read in context does not shift felony costs to cities | Held for Cities: statute construed narrowly; county cannot recover felony inmate medical costs from cities absent an interlocal agreement |
Key Cases Cited
- City of Auburn v. Gauntt, 174 Wn.2d 321 (recognizing counties as primary units handling state-directed justice functions)
- Moore v. Douglas County, 144 Wn.2d 183 (statutory context determines who bears local court-related costs)
- Harrison Mem'l Hosp. v. Kitsap County, 103 Wn.2d 887 (county responsibility for inmate medical costs in certain circumstances)
- State v. Agren, 32 Wn. App. 827 (counties generally bear criminal administration costs absent statutory authority)
- City of Medina v. Primm, 160 Wn.2d 268 (discussing municipal repeal of criminal code provisions and cost consequences)
- State v. Grimes, 7 Wash. 445 (historical authority on county obligations for administering criminal laws)