Childree v. Health Care Authority of the City of Huntsville
In Childree v. Health Care Authority of the City of Huntsville, 548 So. 2d 419 (Ala. 1989), the dispositive issue was which of three entities -- the State of Alabama, the Department of Mental Health, or Madison County -- was financially responsible for the costs incurred in the precommitment care and treatment of indigent Madison County citizens who had been involuntarily committed to the custody of the Department of Mental Health.
The supreme court held that the County was responsible for the costs. The supreme court read 22-52-14, the statute dealing with the payment of costs in civil commitment hearings, in pari materia with 22-21-291, part of the Health Care Responsibility Act, in determining that the County was responsible for the costs of involuntarily committed indigent county citizens.
On remand, the hospital submitted bills to the County for payment. The trial court determined that the Act also limited the amount the hospital could recover.
The hospital appealed, in Health Care Authority of the City of Huntsville v. Madison County, 601 So. 2d 459 (Ala. 1992). The supreme court restated its holding that the County was required to pay hospital bills of indigent residents who had been involuntarily committed to the custody of the Department of Mental Health. 601 So. 2d at 460. The supreme court further held that all sections of the Act were to be read in parimateria with the involuntary-commitment statutes, including those sections of the Act that limit the amount of the hospital's recovery.