Justia Idaho Supreme Court Opinion Summaries

St. Luke’s Meridian Medical Center (St. Luke’s) provided inpatient hospital care for an indigent patient from January 26, 2016, until March 9, 2016. St. Luke’s sought payment from the Board by submitting a medical indigency application. In September 2016, the Board issued an initial determination, only approving payment from January 26 through February 2, 2016. St. Luke’s appealed the denial. The Board amended its determination by only partially extending payment approval through February 18, 2016. St. Luke’s petitioned for judicial review. In October 2017, the district court affirmed the Board’s decision. St. Luke’s appealed to the Idaho Supreme Court, and the Supreme Court held that the Board’s findings did not provide a reasoned analysis, as required by the Idaho Administrative Procedures Act (IDAPA). The case was remanded back to the Board for it to make the required findings of fact and conclusions of law. On remand, the Board entered its findings of fact, conclusions of law, and order, again denying payment and finding that the services provided were not the most cost-effective services as required under the Idaho Medical Indigency Act. St. Luke’s again filed a petition for judicial review, and the district court again affirmed the Board’s decision. Once more, St. Luke’s timely appealed. The Idaho Supreme Court determined the Board’s decision reflected a misinterpretation of the definition of “medically necessary services;” the Board’s decision was set aside and the matter remanded for further proceedings. View "St. Luke's Health System v. Board of Commissioners of Gem County" on Justia Law

An indigent patient was admitted to St. Alphonsus Regional Medical Center (St. Alphonsus) on October 7, 2017, and continued to receive treatment in the hospital until she was discharged on January 12, 2018. During her stay, St. Alphonsus filed a third-party medical indigency application on her behalf, and later filed two additional requests for payment of services. The Board of Ada County Commissioners (the Board) approved payment for dates of service from October 7 until October 10, 2017, but denied payments for services provided from October 11 until December 31, 2017, relying on the opinion of the Ada County Medical Advisor that the services provided on those dates were not “medically necessary” under the definition in Idaho Code section 31-3502(18)A(e). St. Alphonsus appealed the Board’s initial determination, but the final determination upheld the denial for payment beyond October 11. Upon St. Alphonsus’ petition, a district court reversed the Board’s decision, finding that the services “currently available” to a patient were to be considered as a “necessary medical service.” The Board argued “there did exist options for the Patient to proceed to rehabilitation at a facility other than St. Alphonsus, but for the Patient’s lack of funding.” Furthermore, the Board asserted that Idaho Code section 31-3502(18)A(e) is unambiguous in that “[t]here is no wording in [sub]section (e) of the statute that limits the ‘most cost-effective services’ to services that the Patient can afford to pay for.” After review, the Idaho Supreme Court determined the Board exceeded its statutory authority in denying St. Alphonsus reimbursement for providing medically necessary services. “The Board’s denial of payment was not based on substantial evidence and prejudiced St. Alphonsus’ substantial right to compensation for services rendered to an indigent patient.” View "St. Alphonsus Regional Medical v. Ada County" on Justia Law

A group of prisoners (“Petitioners”) sought a writ of habeas corpus based on the conditions of their confinement during the COVID-19 pandemic. The Petitioners were all incarcerated at the Elmore County Jail (“Jail”), contending the conditions of confinement constituted cruel and unusual punishment in violation of the Eighth Amendment to the United States Constitution. More specifically, the Petitioners claimed they were in imminent danger because officials at the Jail did not implement any discernable mitigation measures in response to the COVID-19 pandemic. Elmore County Sheriff Mike Hollinshead and Lieutenant Shauna Gavin (collectively “Officials”) denied this assertion, contending that Petitioners’ request for a writ of habeas corpus should have been denied because the Petitioners did not exhaust their administrative remedies. The Officials filed a motion for summary judgment with the district court, which was granted. The district court also awarded the Officials their attorney fees. Petitioners timely appealed the district court’s decisions to the Idaho Supreme Court, which agreed to hear the appeal on an expedited basis. After that review, the Supreme Court affirmed the district court’s decision granting summary judgment, but reversed the district court’s award of attorney fees. View "Williams v. Hollinshead" on Justia Law

David and Margaret Fisk appealed after a district court granted summary judgment in favor of Jeffery D. McDonald, M.D., and the Hospital on their medical malpractice claims. The district court granted summary judgment on the Fisks’ single cause of action after determining the Fisks had failed to provide expert testimony demonstrating actual knowledge of the community standard of care. The Fisks also appealed the district court’s order denying their subsequent motion for reconsideration. The district court granted summary judgment on the basis that the Fisks failed to establish an essential element of their medical malpractice claim. The Idaho Supreme Court concluded the district court's decision was not based on expert testimony submitted by McDonald or the Hospital. As such, the conclusory nature or admissibility of any such testimony was immaterial to the district court’s decision. Therefore, the district court did not err in determining that the burden was on the Fisks to establish the essential elements of their medical malpractice claim. The Court found, however, that the district court erred in denying the Fisks' motions for reconsideration. The district court was asked to reconsider the order granting summary judgment, so the summary judgment standard applied to the district court’s decision on the motion for reconsideration and now applied to the Supreme Court’s review of that decision on appeal. The Fisks supported their motions for reconsideration with additional expert declarations, one of which demonstrated that he had actual knowledge of the community standard of care. Furthermore, the Supreme Court determined the district court erred in determining that the Fisks failed to properly plead that McDonald was liable for the acts or omissions of a nurse practitioner via the agency theory of liability. The case was remanded for further proceedings. View "Fisk v. McDonald" on Justia Law

Appellants-patients Nathaniel Valencia and Emily Williams were self-pay patients who received emergency medical services at Saint Alphonsus Medical Center—Nampa, Inc. (“Saint Alphonsus”) in 2015. During their respective visits, Patients agreed to pay for “all charges incurred” for services rendered to them. Patients were billed in accordance with Saint Alphonsus’ “chargemaster” rates. Patients sought declaratory relief requesting the district court to rule Saint Alphonsus was only entitled to bill and seek collection of the reasonable value of the treatment provided to self-pay patients. Saint Alphonsus moved the district court to dismiss the complaint pursuant to Idaho Rule of Civil Procedure 12(b)(6). The district court treated the motion to dismiss as a motion for summary judgment pursuant to I.R.C.P. 12(d). Ultimately, the district court granted summary judgment for Saint Alphonsus, and Patients timely appealed. Finding no reversible error, the Idaho Supreme Court affirmed. View "Williams v. St. Alphonsus Medical Center" on Justia Law

Phillip and Marcia Eldridge filed a medical malpractice suit against Dr. Gregory West (West), Lance Turpin, PA-C (Turpin), and Summit Orthopaedics Specialists, PLLC (Summit), alleging Phillip became infected with Methicillin-Resistant Staphylococcus Aureus (MRSA) as a result of malpractice committed by West, Turpin, and agents of Summit. West performed hip replacement surgery on Phillip’s right hip in October 2009. In 2012, West performed what he later described as exploratory surgery on Phillip’s hip to determine the source of Phillip’s pain, as well as the potential replacement of components if an infection were found. All of the test results from the samples sent to the pathology department indicated there was no infection in the hip. Rather than explant the hip in its entirety, West replaced only the metal ball at the head of the femur with a ceramic ball. Following the second surgery, Phillip experienced numerous adverse complications. Phillip would have another revision a few months later, during which the MRSA was discovered. The Eldridges claimed West and Turpin breached the standard of care that was due them and as a result, sustained damages. The district court granted various motions, including a motion to dismiss certain causes of action against West, Turpin, and Summit, as well as a motion for summary judgment brought by Turpin and Summit, and a motion for partial summary judgment brought by West. In their appeal, the Eldridges contended the district court erred by: (1) dismissing their claims for negligent and intentional infliction of emotional distress, gross negligence, and reckless, willful, and wanton conduct; (2) denying their motion to strike the affidavits of West and Turpin; (3) limiting their claim for damages; and (4) concluding that the Eldridges could only present evidence of damages, specifically medical bills, after the Medicare write-offs had been calculated. In affirming in part and reversing in part, the Idaho Supreme Court concluded the district court erred in refusing to strike portions of West’s first affidavit and Turpin’s affidavit because they were conclusory. Furthermore, the district court abused its discretion in precluding the Eldridges from putting on proof of damages that arose after April 24, 2013, and their presentation of damages. Orders granting summary judgment to West regarding the Eldridges’ informed consent claim and Turpin were affirmed. The matter was remanded for further proceedings. View "Eldridge v. West" on Justia Law

Shane and Rebecca Ackerschott sued Mountain View Hospital, LLC, doing business as Redicare (“Redicare”), after Shane sustained an injury leading to paraplegia. A jury found Redicare’s treatment of Shane breached the standard of care and awarded the Ackerschotts $7,958,113.67 in total damages. After judgment was entered, Redicare filed a motion for judgment notwithstanding the verdict, or in the alternative, a new trial. The Ackerschotts also moved to alter or amend the judgment. All post-trial motions were denied. Redicare appealed, arguing the district court erred by not submitting an instruction on comparative negligence to the jury and by allowing testimony of the Ackerschotts’ expert witness. The Ackerschotts cross-appealed, arguing the cap on noneconomic damages imposed by Idaho Code section 6-1603 was unconstitutional. After review, the Idaho Supreme Court affirmed as to Redicare’s direct appeal, and declined to reach the merits of the Ackerschotts’ constitutional claim on cross-appeal. View "Ackerschott v. Mtn View Hospital; Redicare" on Justia Law

This was a permissive appeal brought by Phillip and Marcia Eldridge1 in a medical malpractice action they filed against Dr. Gregory West (West), Lance Turpin, PA-C (Turpin), and Summit Orthopaedics Specialists, PLLC (Summit). The Eldridges alleged that Phillip became infected with Methicillin-Resistant Staphylococcus Aureus (MRSA) as a result of malpractice committed by West, Turpin, and agents of Summit. The Eldridges claimed West and Turpin breached the standard of care that was due them and as a result, sustained damages. The district court granted various motions, including a motion to dismiss certain causes of action against West, Turpin, and Summit, as well as a motion for summary judgment brought by Turpin and Summit, and a motion for partial summary judgment brought by West. On appeal, the Eldridges contended the district court erred in: (1) dismissing their claims for negligent and intentional infliction of emotional distress, gross negligence, and reckless, willful, and wanton conduct; (2) denying their motion to strike the affidavits of West and Turpin; (3) limiting their claim for damages; and (4) concluding that the Eldridges could only present evidence of damages, specifically medical bills, after the Medicare write-offs had been calculated. The Idaho Supreme Court concurred with the Eldridges, reversed the district court and remanded for further proceedings. View "Eldridge v. West, Turpin & Summit" on Justia Law

In 2016, St. Luke’s Health System, Ltd. accepted an indigent patient suffering from meningitis, seizures, and brain lesions. The patient was ready for transfer to another medical facility by February 18, 2016, but was refused by multiple care providers because they did not want to admit an indigent patient without a payor source. St. Luke’s finally contracted with Life Care, another medical facility, to take the patient on the condition that St. Luke’s would guarantee payment for a thirty day period. The patient was transferred to Life Care on March 9, 2016. St. Luke’s applied for medical indigency benefits covering the period of time from the patient’s initial hospitalization until she was transferred to the Life Care facility. Gem County initially approved the application for benefits through February 3, 2016. St. Luke’s appealed that determination, and after a hearing, the Board approved medical indigency benefits from January 26, 2016, until February 18, 2016. The Board entered a written determination titled “Amended Determination of Approval for County Assistance” which set forth the various bills that were approved for payment, but did not in any way reflect the denial of benefits or the reasoning of the Board. St. Luke’s then sought judicial review of the Amended Determination before the district court, which affirmed the Board’s decision. St. Luke’s appealed. The Idaho Supreme Court vacated the Board’s Amended Determination because it did not reflect the partial denial of benefits and because there were no findings of fact or conclusions of law setting forth the basis for the Board’s denial. View "St. Lukes v. Bd of Commissioners of Gem Co" on Justia Law

Saint Alphonsus Regional Medical Center, Inc. (“Saint Alphonsus”) appealed the grant of summary judgment in favor of Ada County Sheriff, Gary Raney, in his official capacity; Ada County; and the Board of Ada County Commissioners, (collectively, “Ada County”). The district court ruled as a matter of law that Ada County was not obligated to pay for an inmate’s (“Patient”) entire hospitalization where the State sought a release from custody during the hospitalization so the inmate could receive medical treatment. The district court ruled that Ada County’s obligation to pay for the hospitalization stopped once a release order was entered. The Idaho Supreme Court held the district court erred in its interpretation of Idaho Code sections 20-605 and 20-612 and vacated the judgment entered in favor of Ada County. View "St. Al's RMC v. Ada Co Sheriff" on Justia Law