## Facts

- Emergency Physicians Integrated Care (EPIC) provided billing and collection services for emergency physicians who treated inmates from the Salt Lake County jail.
- EPIC sought compensation for emergency medical services provided to inmates from February 2000 to November 2004.
- Before a 2001 statutory amendment, the County reimbursed for inmate care under its administrative guidelines and then-applicable Utah Code provisions.
- After the amendment (later codified at Utah Code § 17-50-319), the County reimbursed at noncapitated Medicaid rates and asserted those rates governed payment for inmate medical care.
- EPIC claimed the statute applied to “medical facilities,” not to physicians’ professional fees, and alleged some services were not paid at all.
- EPIC sued the County in quantum meruit for the reasonable value of its physicians’ services.
- The district court granted summary judgment to the County, ruling EPIC did not confer a qualifying “benefit” on the County because the services benefited only the inmates.
- EPIC appealed.

## Issues

1. Whether emergency medical services provided to county inmates conferred a legally cognizable “benefit” on the County sufficient to satisfy the first element of quantum meruit.
2. Whether Utah Code § 17-50-319 forecloses or limits a quantum meruit claim for physicians’ professional fees arising from inmate care.
3. Whether the Utah Governmental Immunity Act, including notice-of-claim requirements, bars EPIC’s claim.

## Decision

- The Utah Supreme Court reversed the grant of summary judgment for the County.
- The court held, as a matter of law, that providing necessary medical care to inmates conferred a benefit on the County because it satisfied or reduced the County’s legal obligation to provide inmate medical care.
- The court remanded for further proceedings, leaving unresolved the remaining quantum meruit elements and defenses, including statutory payment limits and governmental immunity/notice-of-claim issues.

## Legal Principles

- Quantum meruit requires proof that (1) the plaintiff conferred a benefit on the defendant, (2) the defendant knew of or appreciated the benefit, and (3) retention of the benefit without payment would be inequitable.
- A “benefit” for restitution purposes is not limited to a direct, personal, or tangible advantage; it includes the satisfaction or reduction of the defendant’s legal duty.
- The existence of a statutory payment scheme does not, by itself, eliminate equitable restitution where the statute does not clearly displace equitable remedies; any displacement or limitation must be analyzed in context.

## Conclusion

The court ruled that emergency medical care furnished to jail inmates benefits the county by discharging the county’s legal duty to provide such care, making summary judgment improper; the case returned to the trial court to address remaining elements and defenses, including statutory and immunity questions.


Emergency Physicians Integrated Care v. Salt Lake County, 167 P.3d 1080 (Utah 2007)