## Facts

- After a marital dispute, Russell N. Pelo left home, checked into a motel, purchased a shotgun, and called his wife with threats of self-harm.
- Police took Pelo to Ellsworth Municipal Hospital for psychiatric evaluation.
- A magistrate, acting under Iowa’s emergency hospitalization procedure, found probable cause that Pelo was seriously mentally impaired and likely to physically injure himself and ordered detention for up to 48 hours for examination and care.
- On admission, the hospital presented an admission form stating Pelo (or his insurer) would be responsible for charges not covered by insurance; he initially refused but later signed.
- Pelo remained hospitalized from January 8 to January 13, 1995, receiving psychiatric evaluation and care.
- A later involuntary-commitment hearing resulted in a finding that continued involuntary hospitalization was not justified, and further commitment was denied.
- Pelo refused to pay the hospital bill and refused to authorize his insurer to pay.
- The hospital assigned the debt to Credit Bureau Enterprises, Inc., which obtained judgments for the charges in small claims and district court; Pelo appealed.

## Issues

1. Whether a patient involuntarily hospitalized for mental health treatment may be held personally liable in restitution (quasi-contract/unjust enrichment) for the reasonable value of necessary medical services when meaningful consent was lacking due to serious mental impairment.
2. Whether the signed admission form was enforceable given claimed duress and incapacity.
3. Whether Iowa’s mental-health statutes shifted payment responsibility away from the patient and barred restitution against him.

## Decision

- The Iowa Supreme Court affirmed judgment for Credit Bureau Enterprises.
- Pelo was personally liable for the reasonable value of necessary psychiatric services provided during the involuntary hospitalization.
- Recovery was proper under restitution/quasi-contract principles regardless of whether the admission form created an enforceable express contract.
- The statutory scheme did not make the county responsible for these charges or displace restitutionary liability.

## Legal Principles

- A contract implied in law (quasi-contract) is imposed by law without regard to the parties’ assent to prevent unjust enrichment.
- Restitution is available when a provider, not acting officiously, confers a benefit through necessary services and it would be unjust for the recipient to retain the benefit without payment.
- When consent is impossible or immaterial due to mental impairment, the law may impose an obligation to pay for necessary medical services even if the recipient did not request them.
- The legal justification and necessity of emergency services are assessed at the time provided; a later determination that continued commitment is unwarranted does not negate liability for earlier necessary care.
- Absent a statutory provision reallocating costs, common-law restitution may require the recipient of necessary medical services to pay their reasonable value.

## Conclusion

The court held that necessary psychiatric services provided during a lawful emergency involuntary hospitalization conferred a compensable benefit, and equity required the patient to pay their reasonable value under quasi-contract principles even without meaningful consent or an enforceable express agreement.


Credit Bureau Enters., Inc. v. Pelo, 608 N.W.2d 20 (Iowa 2000)