Tama County v. Grundy County

Summary

The Supreme Court of Iowa held that a county of legal settlement must reimburse another county for the costs of an involuntary hospitalization in a private hospital when the services were authorized through the single-entry-point process. The court affirmed the judgment requiring Grundy County to reimburse Tama County for medical and hospital expenses incurred for S.P.

Holdings

1. A county of legal settlement is liable for costs and expenses associated with a person with mental illness when the services and support were authorized through the single-entry-point process, even if the involuntary hospitalization occurred in a private hospital rather than a state hospital.
2. For a court-ordered involuntary hospitalization, the statutory reference to authorization through the single-entry-point process refers to the process of the county in which the emergency or involuntary commitment is ordered.

Questions Presented

1. Whether Iowa Code section 230.1, as amended in 1996, required the county of a patient's legal settlement to reimburse another county for involuntary hospitalization expenses incurred at a private hospital when the services were authorized through the single-entry-point process.
2. Whether the single-entry-point process applicable to a court-ordered involuntary hospitalization is the process of the county in which the emergency or involuntary commitment is ordered.

Disposition

affirmed