## Facts

- Two infants who resided in Minidoka County, Idaho, required specialized medical treatment and were transferred to the University of Utah Hospital and Medical Center in Utah.
- The hospital provided inpatient care and submitted reimbursement claims to Minidoka County under Idaho’s medical indigency statutes (Idaho Code tit. 31, chs. 34–35).
- The governing statutory definition, Idaho Code § 31-3502(2), defined “hospital” as a facility “licensed as such in Idaho” that provides specified inpatient services.
- Minidoka County denied payment on the ground that the hospital was not licensed in Idaho and therefore did not qualify as a “hospital” under the statutes.
- The hospital sued the county clerk and county commissioners seeking payment; the district court granted summary judgment for the county, and the hospital appealed.

## Issues

1. Whether Idaho’s medical indigency statutes obligate a county to reimburse an out-of-state hospital for care provided to county residents when the statutory definition of “hospital” is limited to facilities “licensed as such in Idaho.”

## Decision

- The Idaho Supreme Court affirmed summary judgment for Minidoka County.
- The court held that Idaho Code § 31-3502(2) restricts “hospital” to facilities licensed in Idaho.
- Because the University of Utah Hospital was not licensed in Idaho, the county had no statutory duty to reimburse it under the medical indigency statutes.

## Legal Principles

- When the legislature supplies a definition in a statute, courts and administering officials must apply that definition as written.
- Clear statutory text controls over policy and fairness arguments; courts may not expand coverage by adding terms the legislature did not enact.
- Under Idaho Code § 31-3502(2), a facility not licensed in Idaho is not a “hospital” eligible for county reimbursement under the medical indigency scheme.

## Conclusion

The court enforced the statutory definition limiting “hospital” to Idaho-licensed facilities and held that Minidoka County was not liable to reimburse an out-of-state hospital for treatment provided to medically indigent county residents absent legislative authorization.


Univ. of Utah Hosp. & Med. Ctr. v. Bethke, 101 Idaho 245, 611 P.2d 1030 (Idaho 1980)