Salts v. Lancaster County

Summary

The Supreme Court of Nebraska held that Lancaster County exceeded its statutory authority by imposing durational and other residency requirements that limited general assistance medical benefits for eligible indigent persons located in the county. Construing Nebraska’s general assistance statutes together, the court concluded that counties must provide the minimum level of necessary care established under their programs to eligible persons regardless of county residence, subject to reimbursement rights against the recipient’s county of legal settlement. The court reversed the district court and remanded for further proceedings.

Holdings

1. Lancaster County exceeded its statutory authority by adopting General Assistance Guidelines 2:101 and 3:101 to limit medical assistance to otherwise eligible persons who lacked county residency or whose medical condition did not meet the guidelines' additional requirements.
2. A county must provide all eligible persons located within the county, whether county residents or nonresidents, the minimum level of medical care necessary to maintain health and decency that the county has undertaken to provide under Neb. Rev. Stat. § 68-133(2).

Questions Presented

1. Whether Lancaster County exceeded its statutory authority by imposing durational and condition-based residency requirements on indigent persons seeking primary health care benefits under the county's general assistance program.
2. Whether Nebraska's general assistance statutes require a county to provide the same minimum level of necessary medical care to eligible persons located in the county regardless of whether they have legal settlement there.

Disposition

reversed_and_remanded