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Constitutional Law Keyed to Choper
Memorial Hospital v. Maricopa County
Citation:
415 U.S. 250 (1974)Facts
In June 1971, Henry Evaro, an indigent suffering from chronic asthmatic and bronchial illness, moved from New Mexico to Phoenix in Maricopa County, Arizona. On July 8, 1971, Evaro had a severe respiratory attack and was sent by his physician to Memorial Hospital, a private nonprofit community hospital. Following Arizona law, Memorial notified the Maricopa County Board of Supervisors that it had an indigent patient who might qualify for county care and requested reimbursement of $1,202.60 for services provided. The county refused to admit Evaro to its public hospital or reimburse Memorial solely because Evaro had not been a resident of the county for the preceding 12 months, as required by Arizona law. The county did not dispute that Evaro was indigent or a bona fide resident of Maricopa County. Arizona law provided an exception to the 12-month requirement only for “emergency cases when immediate hospitalization or medical care is necessary for the preservation of life or limb.”
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