St. Al's RMC v. Elmore County
Annotate this CaseAppellant Saint Alphonsus Regional Medical Center submitted third party medical indigency applications on behalf of two patients. Respondent Elmore County and the Board of Elmore County Commissioners denied the applications because the Board determined that the applications were incomplete. Saint Alphonsus filed petitions for judicial review. The district court consolidated the cases and affirmed the Board’s decision. The issue presented for the Supreme Court's review centered on the statutory interpretation of the Medical Indigency Act. Specifically, the issue reduced to whether a third party’s application for financial assistance (Saint Alphonsus) was a “completed application” with signatures from only the third party applicant and not the patient. The two relevant provisions for this issue were Idaho Code sections 31-3502(7) and 31-3504(1). Based on its interpretation of these statutes, the Supreme Court held that a third party’s application was a “completed application” with signatures from only the third party applicant, therefore the application did not require the signature of the patient to be “completed” under the Act. The Court vacated the district court's judgment and remanded the case for further proceedings.
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