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Credit Bureau Enterprises, Inc. v. Pelo

Iowa Supreme Court
608 N.W.2d 20 (2000)


Facts

Pelo (defendant) left his residence after arguing with his wife and checked into a hotel. Pelo purchased a shotgun and called his wife making threats of self harm. The police were informed of his threats and they took him to the hospital. Pursuant to emergency hospitalization procedures, a probable cause hearing was held and the magistrate found that Pelo was seriously mentally impaired and likely to injure himself physically. The magistrate entered an emergency hospitalization order for 48 hours. Pelo remained at the hospital from January 8-13. The hospital sought compensation for medical services provided during this stay. Pelo refused to pay or authorize his insurance company to do so. The hospital assigned its claim against Pelo to Credit Bureau Enterprises, Inc. (Credit Bureau) (plaintiff). Credit Bureau filed suit against Pelo for the hospital charges in small claims court. The court found in favor of Credit Bureau. Pelo appealed to the district court. The district court found in favor of Credit Bureau. Pelo appealed to the Iowa Supreme Court.

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Holding and Reasoning (McGiverin, C.J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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