County of Erie v. Axelrod, 63 N.Y.2d 731 (1984)

Under New York Public Health Law, a county is not entitled to state reimbursement for expenditures of its medical examiner’s office unless the office is subject to the jurisdiction of the county’s department of health, and the medical examiner’s laboratory services are not reimbursable under Section 620 unless the laboratory is established pursuant to Article 5 of the Public Health Law and provides patient services or services to health officers for sanitary purposes.

Summary

Erie County sought state reimbursement for expenditures made by its medical examiner’s office. The New York Court of Appeals held that the county was not entitled to reimbursement because the medical examiner’s office was not under the jurisdiction of the county’s health department as required by Public Health Law § 608 and because the office’s laboratory services did not meet the criteria for reimbursement under Public Health Law § 620. The court emphasized that the legislature intended to encourage the development of local health departments, and the reimbursement scheme reflected this policy. The court further clarified that Section 620 only applies to laboratories providing patient services or services for sanitary purposes, which the medical examiner’s office did not exclusively provide.

Facts

Erie County sought state reimbursement for expenditures of its medical examiner’s office, including laboratory services. The County argued that these expenditures were reimbursable under Sections 608 and 620 of the Public Health Law. The Commissioner of Health denied reimbursement, arguing that the medical examiner’s office was not subject to the jurisdiction of the county’s health department, and that the laboratory services did not qualify under the statutory criteria for reimbursement.

Procedural History

The lower court ruled in favor of the County of Erie. The Appellate Division affirmed. The New York Court of Appeals reversed the Appellate Division’s order and declared the Commissioner’s regulation valid, effectively denying the reimbursement sought by the County.

Issue(s)

1. Whether Erie County is entitled to state reimbursement for the expenditures of its medical examiner’s office under Public Health Law § 608, given that the office is not subject to the jurisdiction of the county’s department of health.
2. Whether the laboratory services provided by the Erie County medical examiner’s office are reimbursable under Public Health Law § 620.

Holding

1. No, because under Public Health Law § 608, reimbursement for general public health expenditures to a county with a health department is only available for expenditures by that department or designated agencies outside the department, and the medical examiner’s office was neither.
2. No, because Public Health Law § 620 provides reimbursement only for laboratories established pursuant to Article 5 of the Public Health Law that provide patient services or services to health officers for sanitary purposes, and the medical examiner’s office did not meet these criteria.

Court’s Reasoning

The Court reasoned that Section 608 of the Public Health Law only allows reimbursement for expenditures made by the county’s health department or agencies specifically designated by the department for particular health programs. Because the medical examiner’s office was an external agency not expressly authorized for reimbursement under Section 608, its expenditures were not reimbursable. The court emphasized that the legislative intent behind Section 608 was to encourage the development of local health departments. The court stated that, “It is designed to encourage the development of local health departments and the improvement of health services generally” (NY Legis Ann, 1946, p 188). The court also rejected the argument that the medical examiner’s laboratory services were reimbursable under Section 620. It noted that Section 620 only applies to laboratories established under Article 5 of the Public Health Law. Furthermore, Section 580(2) of Article 5 states that the title regulates “only activities which constitute patient services or services provided to health officers or their agents for sanitary purposes.” The court found that the medical examiner’s office activities did not exclusively fall within these categories, and thus, reimbursement was not warranted. The court explicitly rejected the Appellate Division’s reliance on the general purpose statement of section 570 or the definition of “clinical laboratory” in section 571(1), finding that title V of article 5 was meant to regulate only services to patients or for sanitary purposes.