Emergency Physicians Integrated Care v. Salt Lake Cty. - 2007 UT 72, 167 P.3d 1080 (Sup.Ct.)

Rule:

The U.S. Constitution requires that the government provide medical care to persons convicted or detained by a government entity. Consequently, medical care is logically included in Utah Code Ann. § 17-50-319(1)(c)'s broad requirement that an entity pays the expenses "necessarily incurred in the support" of pretrial or convicted inmates. 

Facts:

Appellant, Emergency Physicians Integrated Care was formed for the purpose of providing billing and collection services to various emergency physicians. Appellant sued appellee Salt Lake County under a theory of quantum meruit compensation for medical services its physicians provided to county inmates. The appellant contended that Utah Code Ann. § 17-50-319 (2005) rendered the appellee liable for the cost of inmates' medical care. The appellee denied the applicability of the general obligation contained in § 17-50-319(1)(c), claiming that it was superseded by the specific language of subsections (1)(k) and (2). The district court entered summary judgment in favor of the appellee, holding that the appellant’s services failed to benefit the county as required by the first prong of a quantum meruit analysis. The appellant provider appealed.

Issue:

Did the appellant’s services failed to benefit the appellee as required by the first prong of a quantum meruit analysis?

Answer:

No. The court reversed the district court's order.

Conclusion:

The court agreed with the appellant. The court held that the U.S. Constitution required the appellee to provide medical care to persons convicted or detained by it. As medical care was logically included in subsection (c)'s broad requirement that the appellant county pays the expenses necessarily incurred in the support of pretrial or convicted inmates. The court further held that by their express terms, subsections (1)(k) and (2) governed only services provided by medical facilities, services that were distinct from medical care provided by physicians. And because (1)(k) and (2) had no application to physicians, subsection (1)(c) applied and the county had a statutorily mandated duty to pay for the services. The physicians conferred a benefit by providing the means by which the county fulfilled its obligation to provide inmate care. Therefore, because the evidence created a dispute on the reasonable value of the services, a remand was required.