City of Revere v. Massachusetts General Hospital
Headline: Court limits federal duty: cities must secure medical care for people hurt by police but are not automatically required to pay hospitals; billing and payment are left to state law and local policy.
Holding: The Court held that a city must ensure necessary medical care for a person injured by its police but the Federal Constitution does not require the city to reimburse the hospital; payment allocation is governed by state law.
- Cities must ensure medical care for people injured by police but are not federally required to reimburse hospitals.
- Leaves allocation of hospital payment to state law or local decisions.
- Could push police to use public hospitals or services based on cost, not distance.
Summary
Background
The dispute involves Massachusetts General Hospital (a private hospital) and the City of Revere. Police officers shot and injured Patrick Kivlin while trying to detain him, and took him to the hospital. MGH treated him, billed the city, and the city refused to pay. The state supreme court held that the Eighth Amendment required Revere to pay the hospital for the first stay, and the Supreme Court agreed to review that constitutional holding.
Reasoning
The Court explained that the Eighth Amendment applies to convicted prisoners and not to persons who have not been adjudicated guilty. The more relevant protection is the Due Process Clause, which requires that a person injured while being apprehended receive needed medical care. But the Court held that providing care and paying for it are different questions: the Constitution requires the city to see that care is provided, but it does not automatically force the city to reimburse the hospital for costs. How costs are allocated is a matter for state law or policy, unless payment is the only way the city can secure care.
Real world impact
As a result, hospitals cannot rely on the Federal Constitution to force cities to pay medical bills after police injuries. Cities remain responsible to make sure injured people are treated, but states and local governments decide who pays. This may affect hospital billing practices and choices about which hospitals police use.
Dissents or concurrances
Justices Rehnquist and White said the Court need not decide the Due Process standard here because Revere had already arranged prompt care. Justice Stevens viewed the case as a state fiscal policy issue and joined the judgment.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?