Harrison Memorial Hospital v. Kitsap County

Citations: 700 P.2d 732; 103 Wash. 2d 887Docket: 50213-7

Court: Washington Supreme Court; May 30, 1985; Washington; State Supreme Court

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RCW 70.48.130 mandates Kitsap County to cover post-incarceration medical expenses incurred by Charles Schickler at Harrison Memorial Hospital. Schickler was jailed for investigation of crimes and attempted suicide, leading to his hospitalization where he remained comatose until his death. Kitsap County failed to inform Harrison of its limited financial responsibility for Schickler's medical expenses, which prompted Harrison to file a claim for $61,613.45 and, subsequently, a lawsuit for ongoing costs. The trial court ruled in favor of Harrison, affirming that the case hinges on state law concerning medical service allocations rather than constitutional obligations, as Kitsap County had met its federal responsibilities by ensuring Schickler received necessary medical attention. RCW 70.48.130 specifies that governing units are responsible for emergency healthcare costs, with potential reimbursement from the department for eligible individuals under public assistance programs.

The governing unit, defined as the county or city operating the jail, can seek reimbursement for emergency and health care costs from a confined individual, contingent on their financial ability and available insurance. If the individual cannot pay and is ineligible for financial assistance, the governing unit may recover costs from the government entity whose law enforcement initiated the charges. Specifically, the state is responsible for costs related to state prisoners accused of escaping or committing offenses in state facilities. 

In this case, Kitsap County acknowledges its obligation to cover Schickler's medical expenses for the first 72 hours of confinement but argues that its responsibility ended after this period, as Schickler was neither indicted nor charged. The County references CrR 3.2A(c)(1), which establishes that a person cannot be detained beyond 72 hours without formal charges, excluding weekends and holidays. Therefore, the County claims it was not the governing unit after this timeframe.

Harrison, the healthcare provider, counters that CrR 3.2A(c)(1) does not dictate the payment for an indigent prisoner’s medical care and argues that the County's interpretation of 'confined' may be too narrow. Despite not formally arraigning Schickler, the County was aware that his medical condition precluded him from leaving the jurisdiction, suggesting that formal confinement was unnecessary to ensure his appearance for arraignment. Other jurisdictions have encountered similar issues regarding the provision of medical care to confined individuals.

Medical expenses for individuals in custody are the responsibility of the County, as outlined in Or. Rev. Stat. 169.150. Charles Fortney, who was shot while committing burglary, was hospitalized for spinal cord injuries leading to paralysis. Although Fortney was released on his own recognizance on June 20, 1975, he remained hospitalized until July 29, 1975. The hospital claimed he was 'in custody' during this period and sought payment from the County. The court determined that statutory liability for hospitalization extends to situations implying the prisoner remains in custody, regardless of formal procedures. This precedent was supported by subsequent cases that defined 'custody' broadly, including instances when a prisoner cannot leave a hospital due to physical conditions. The County’s obligation to pay for Fortney’s treatment was established, aligning with similar rulings in other jurisdictions.

In relation to Schickler, the County similarly argued against liability for his medical expenses due to potential federal funds available to him. However, the court maintained that Schickler was effectively in custody during his hospitalization, reinforcing the County's responsibility for his medical costs, as no evidence suggested the County would have released him if able. Thus, the County is liable for Schickler's medical expenses incurred at Harrison. Additionally, the County asserted a right to reimbursement from any federal funds received by Schickler.

In 1946, Congress passed the Hospital Survey and Construction Act, known as the Hill-Burton Act, which allocates federal funds for hospital construction and modernization, contingent upon providing services to those unable to pay. Harrison Memorial Hospital acknowledges receiving Hill-Burton funds, thus offering free medical care to indigent individuals. However, the hospital contends that these funds do not constitute a medical benefit program accessible to patient Schickler. The argument is reinforced by a case, St. Michael Hosp. of Franciscan Sisters v. County of Milwaukee, where the Wisconsin Supreme Court ruled that hospitals must seek payment from local counties before utilizing Hill-Burton funds. Consequently, the court determined that the Hill-Burton Act was not a valid defense in collection actions by hospitals. The summary concludes that Kitsap County is responsible for Schickler's healthcare costs during his hospitalization, as Hill-Burton funds cannot offset the county's obligation. The trial court's summary judgment favoring Harrison Memorial Hospital is upheld. Additionally, it is noted that Schickler faced a murder charge, which was dismissed due to his condition.