St. Luke's Regional Medical Center, Ltd. v. Board of Commissioners of Ada County, Idaho

2009 Opinion No. 25 (Supreme Court of the State of Idaho 2009) · Supreme Court of the State of Idaho · March 4, 2009 · No. 34953

Summary

The Idaho Supreme Court held that a medical provider has standing to seek judicial review of a county board's final decision denying a medical indigency application under Idaho Code § 31-3505G. The court concluded that the 1996 statutory amendments did not overturn prior precedent recognizing providers as real parties in interest. The district court's dismissal of St. Luke's petition was vacated, and the case was remanded for further proceedings.

Holdings

  1. A medical provider with a pecuniary expectation of compensation is a real party in interest and continues to have standing to seek judicial review of a county board's final decision denying a medical indigency application under Idaho Code § 31-3505G.

Questions Presented

  1. Whether a medical provider has standing under Idaho Code § 31-3505G to seek judicial review of a final decision by a county board of commissioners denying a medical indigency application.

Disposition

vacated

Cases Cited (20)

  • State v. Yzaguirre, 144 Idaho 471, 163 P.3d 1183 (2007)(followed)
  • George W. Watkins Family v. Messenger, 118 Idaho 537, 797 P.2d 1385 (1990)(followed)
  • Payette River Property Owners Ass'n v. Board of Commissioners of Valley County, 132 Idaho 551, 976 P.2d 477 (1999)(followed)
  • Gillihan v. Gump, 140 Idaho 264, 92 P.3d 514 (2004)(followed)
  • Kelso & Irwin, P.A. v. State Insurance Fund, 134 Idaho 130, 997 P.2d 591 (2000)(followed)
  • J.R. Simplot Co. v. Western Heritage Insurance Co., 132 Idaho 582, 977 P.2d 196 (1999)(followed)
  • Carrier v. Lake Pend Oreille School District No. 84, 142 Idaho 804, 134 P.3d 655 (2006)(followed)
  • University of Utah Hospital v. Ada County Board of Commissioners, 143 Idaho 808, 153 P.3d 1154 (2007)(followed)
  • Carpenter v. Twin Falls County, 107 Idaho 575, 691 P.2d 1190 (1984)(followed)
  • Carrington v. Crandall, 63 Idaho 651, 124 P.2d 914 (1942)(followed)

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