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Washington Superior Court Says Jail Cannot Bill Poor Detainees for Medical Care

by Douglas Ankney

On April 17, 2023, Judge Kevin S. Naught of Washington’s Yakima County Superior Court ruled that Kittitas County Corrections Center (KCCC) was in violation of state law when it held detainees responsible for repaying the costs of their medical care while confined without a judicial determination of their ability to pay made at sentencing or judgment.

When Robert Mikel Lambert was booked into the jail in 2016, he was required to sign several forms acknowledging that he would be “financially responsible for any and all medical care” that he received while in custody. The forms also explained that “[c]harges for health care will remain on your account even after you leave the facility.”

“Inmates will have thirty days from the date of their release from this facility to pay your account in full,” the forms warned, adding that accounts over 30 days past due “will be turned over to a collection agency.”

While in custody at KCCC, Lambert experienced a medical emergency stemming from an infection, requiring transport to Kittitas Valley Hospital (KVH) on five separate occasions. On August 10, 2016, KCCC gave Lambert a “stack of receipts” for these treatments and informed him that he owed $11,422.52. Lambert objected in grievances. All were denied based on KCCC’s policy and the forms he had signed.

After Lambert was transferred to prison to serve a 55-month sentence, his balance was submitted to a collections agency, Armada Corp. By February 10, 2017, the debt had grown to $12,820.59 with interest. On March 11, 2020, with the assistance of attorneys from Columbia Legal Services in Seattle, Lambert sued the county, Sheriff Clayton Myers and KCCC Superintendent Steve Panattoni, alleging that the jail’s policy violated state law. The parties moved for summary judgment.

The Superior Court observed that “[t]here are no genuine issues of material fact in dispute” but rather the “question before the Court is purely a question of law.” Under state law, RCW 70.48.130, KCCC was supposed to submit a detainee’s medical expenses at the judgment and sentencing phase for a determination of his ability to pay, the Court said. “Not submitting the costs for a judge to review, holding the expenses, and sending them to collections contradicts the intent of the statutory scheme,” the Court declared.

Because the forms that Lambert signed were “contrary to the plain language” of the law, they were unenforceable, the Court said. Specifically, language on the forms that placed the burden on him to make payment arrangements directly with the jail’s health care providers contradicted the law’s mandate making the government responsible for payment if a detainee is determined indigent.

Accordingly, respondents were ordered to “[d]ischarge all medical debt that was unlawfully attributed to Mr. Lambert’s account” and to “alert any collections agencies” involved with its recovery that the debt “has been discharged.” The Court further ordered the jail to rewrite its policy and revise affected forms to reflect that it is KCCC’s responsibility to cover healthcare costs depending on a detainee’s court-determined ability to pay. The jail was also ordered to create a procedure for sending medical debts to the Court for an ability-to-pay determination as part of a judgment or sentence. See: Lambert v. Kittitas County, Wash. Super. (Yakima Cty.), Case No. 20-2-00874-39 (2023).   

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Related legal case

Lambert v. Kittitas County