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Newton Medical Center v. D.B.

Superior Court of New Jersey, Appellate Division

January 17, 2018

NEWTON MEDICAL CENTER, Plaintiff-Respondent,
D.B., Defendant-Appellant.

          Argued October 26, 2017

         On appeal from Superior Court of New Jersey, Law Division, Special Civil Part, Warren County, Docket No. DC-1810-14.

          Richard A. Mastro argued the cause for appellant (Legal Services of Northwest Jersey, Inc., attorneys; Richard A. Mastro, on the briefs).

          Anthony J. Her argued the cause for respondent (The Law Offices of Richard W. Krieg, LLC, attorneys; Anthony J. Her and John T. Grogan, Jr., of counsel and on the brief).

          Before Judges Simonelli, Haas and Rothstadt.


          ROTHSTADT, J.A.D.

         In this appeal, we are asked to determine whether a patient who requires emergent psychiatric treatment, resulting in his involuntary commitment to a hospital, should be treated differently for charity care purposes than a patient who suffers a physical injury or illness. This issue of first impression arises from a dispute regarding a hospital's attempt to recover payment from an indigent mental health patient, who was involuntarily committed to its facility after being screened by a psychiatric emergency screening service (PESS), when the hospital followed the charity care procedures applicable to a non-emergent admission instead of those applicable to an admission through the hospital's emergency room. The trial court determined on summary judgment that the procedures governing a regular admission applied, and the hospital was entitled to recover from the patient based on a theory of quasi-contract. We disagree and reverse.

         For the reasons that follow, we hold that when a mental health patient is admitted to a hospital on an emergent basis through the referral of a PESS, the provisions of the charity care regulations dealing with emergency room admissions apply.

         The facts giving rise to plaintiff, Newton Medical Center's claim for payment from defendant, D.B., [1] are undisputed. Defendant, a diagnosed schizophrenic, was involuntarily committed to plaintiff's short-term care facility (STCF)[2] on an emergent basis after he experienced a psychotic episode and the Warren County PESS determined that he was a danger to himself and others. After receiving treatment at plaintiff's STCF from February 19 to February 28, 2013, defendant accumulated a bill of $6745.50, [3] which he did not pay.

         Defendant's reported income in 2013 was well below the poverty level, making him eligible for uncompensated care under New Jersey's Charity Care Program, N.J.A.C. 10:52-11.1 to -11.17.[4] Defendant filled out and signed a charity care application, but was advised that the application could not be processed because he did not provide all of the requisite documentation. Due to his condition, [5] defendant failed to provide the documents within the allotted regulatory time period. Plaintiff billed defendant, and subsequently sent four letters demanding payment to defendant's mother's address, where defendant was residing.[6] After he defaulted, plaintiff filed suit for recovery of the unpaid bill.

         Before trial, the parties filed cross-motions for summary judgment. Defendant argued that plaintiff's claim was barred by the payments it received from the DMHS. He contended that the express contract between the State and plaintiff barred plaintiff from recovering from him on a theory of unjust enrichment because plaintiff could not have expected remuneration from defendant. Defendant also asserted that plaintiff could not recover because it failed to follow the charity care application provisions of N.J.A.C. 10:52-11.16, which governs emergency admissions. Plaintiff opposed defendant's motion, arguing that N.J.A.C. 10:52-11.16 was only applicable to patients admitted through the emergency room, and that the provisions governing regular admission were properly followed in defendant's case. In its cross-motion, plaintiff maintained that because the facts were undisputed and defendant presented no valid defenses, it was entitled to judgment as a matter of law.

         Upon considering their submissions, the motion judge denied defendant's motion and granted plaintiff's cross-motion. As a threshold matter, the judge found that a quasi-contract existed between plaintiff and defendant, which entitled plaintiff to recover for the services it provided. Relying on the plain meaning of the regulations, the judge rejected defendant's argument that he should be afforded the benefit of the same "stringent" regulations applied to charity care applicants admitted to a hospital through its emergency room for treatment of physical injuries or illnesses. In his written statement of reasons, the judge noted "defendant . . . provided no evidence that he was admitted through an emergency room[, ]" which relieved plaintiff of the screening requirements found in N.J.A.C. 10:52-11.16. The judge entered orders on March 10, 2016[7] denying defendant's motion and granting plaintiff's cross-motion.

         Defendant moved for reconsideration of the motion judge's grant of summary judgment in favor of plaintiff and denial of his motion for summary judgment. The judge entered an order denying reconsideration on July 6, 2016.[8] In his written statement of reasons, the judge again explained:

The more stringent emergency room charity care regulations apply only "[i]f a charity care applicant is admitted through the hospital's emergency room." [N.J.A.C.] 10:52-11.16. The plain language of the regulation requires an admission through the hospital's emergency room, in this case [plaintiff's]. It does not apply to [a] transfer from an emergency screening service or even from another hospital's emergency room.

         Defendant's appeal from the motion judge's grant of summary judgment and denial of reconsideration followed.[9]

         We review a trial court's order granting summary judgment de novo, applying the same standard as the trial court. Conleyv. Guerrero, 228 N.J. 339, 346 (2017). That standard commands that summary judgment be entered "if the pleadings, depositions, answers to interrogatories and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact challenged and that the moving party is entitled to a judgment or order as a matter of law." R. 4:46-2(c). When no issue of fact exists, and only a question of law remains, we afford no special deference to the legal determinations of the trial court. Manalapan Realty, L.P. v. Twp. Comm. of Manalapan, 140 N.J. 366, 378 (1995). Because ...

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