The facts giving rise to plaintiff, Newton Medical Center's claim for payment from defendant, D.B., 1 are undisputed. We disagree and reverse.įor 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 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. 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. 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. Grogan, Jr., of counsel and on the brief). Iler argued the cause for respondent (The Law Offices of Richard W. Mastro argued the cause for appellant (Legal Services of Northwest Jersey, Inc., attorneys Richard A. A-5101-15T4 Decided: January 17, 2018īefore Judges Simonelli, Haas and Rothstadt. NEWTON MEDICAL CENTER, Plaintiff-Respondent, v. Superior Court of New Jersey, Appellate Division.
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