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Health Law Keyed to Furrow
Provena Covenant Medical Center v. Department of Revenue
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*Case Brief Anatomy includes: Brief Prologue, Complete Case Brief, Brief Epilogue
- The Brief Prologue provides necessary case brief introductory information and includes:
- Topic: Identifies the topic of law and where this case fits within your course outline.
- Parties: Identifies the cast of characters involved in the case.
- Procedural Posture & History: Shares the case history with how lower courts have ruled on the matter.
- Case Key Terms, Acts, Doctrines, etc.: A case specific Legal Term Dictionary.
- Case Doctrines, Acts, Statutes, Amendments and Treatises: Identifies and Defines Legal Authority used in this case.
- The Case Brief is the complete case summarized and authored in the traditional Law School I.R.A.C. format. The Pro case brief includes:
- Brief Facts: A Synopsis of the Facts of the case.
- Rule of Law: Identifies the Legal Principle the Court used in deciding the case.
- Facts: What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case. Review the Facts of this case here:
Provena Hospitals (Plaintiff), one of four subsidiaries of Provena Health, owns and operates six hospitals, including Provena Covenant Medical Center (PCMC) (Plaintiff), a full-service hospital. Provena Hospitals is exempt from federal income tax. The Illinois Department of Revenue (Defendant) determined that while PCMC (Plaintiff) was exempt from retailers' occupation tax, service occupation tax, use tax, and service use tax, it was not entitled to a property tax exemption for charitable organizations based on analysis of the actual amount of "charity" it provided to the community. For example, the amount of aid provided by Provena Hospitals (Plaintiff) to PCMC (Plaintiff) patients under the facilities charity care program equaled only 0.723 percent of PCMC's (Plaintiff) revenues (which was $268,276 less than the $1.1 million in property tax benefits which PCMC sought). Provena Hospitals (Plaintiff) ascribed $25,282,000 of its $739,293,000 total revenue to "other revenue," with no showing as to how much, if any, of it was derived from charitable contributions. Charitable donations made to PCMC (Plaintiff) were only $6,938. Following the denial of the property tax exemption, Provena (Plaintiff) sought review through a suit in state court.
- Issue(s): Lists the Questions of Law that are raised by the Facts of the case.
- Holding: Shares the Court's answer to the legal questions raised in the issue.
- Concurring / Dissenting Opinions: Includes valuable concurring or dissenting opinions and their key points.
- Reasoning and Analysis: Identifies the chain of argument(s) which led the judges to rule as they did.
- The Brief Prologue closes the case brief with important forward-looking discussion and includes:
- Policy: Identifies the Policy if any that has been established by the case.
- Court Direction: Shares where the Court went from here for this case.