SHARP HEALTHCARE v. County of San Diego

A group of hospitals including Sharp Memorial Hospital (referred to collectively as Sharp ) sued the San Diego County Sheriff’s Department and the County of San Diego (County) after the County notified the hospitals that it would no longer pay for the medical care expenses of arrestees who receive treatment at the hospitals before they are booked or otherwise committed into county jail (referred to in this opinion as precommitment arrestees). The dispute arose from the parties’ conflicting interpretations of several statutes which were amended in 1992 (Pen. Code, § 4015; Gov. Code, § 29602), and an appellate court decision decided before the amendments (Washington Township Hosp. Dist. v. County of Alameda (1968) 263 Cal.App.2d 272 [ 69 Cal.Rptr. 442 ] (Washington Township)). Both parties filed motions for summary adjudication, asking the trial court to declare the parties’ rights on the issue of the County’s liability. Sharp requested a ruling declaring that the County was financially responsible for an arrestee’s medical care expenses prior to booking into county jail, whereas the County requested a ruling declaring that it did not have this financial responsibility…