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Eastern Kentucky Welfare Rights Organization v. Simon

United States Court of Appeals for the District of Columbia Circuit
506 F.2d 1278 (1974)


Federal tax laws provided benefits to charitable organizations, including an exemption from having to pay federal income tax. These benefits applied to hospitals; however, simply being a hospital was not enough to qualify as a tax-exempt charity. In the 1950s, to be a tax-exempt charity, a hospital was also required to provide medical services at free or reduced costs to people who had trouble paying. In 1969, the federal tax laws were changed to allow hospitals to be tax-exempt charities even if they provided no free services. Instead, a new law required any tax-exempt hospital to provide (1) an emergency room that would treat people even if the people could not pay the charges and (2) general hospital services to anyone who could pay directly or through any form of health insurance, including Medicare and Medicaid. At one point in history, hospitals provided care mostly to poor people who could not pay for private doctors. By 1969, hospitals treated both rich and poor people, and Medicare and Medicaid were important programs that provided healthcare coverage for a large percentage of indigent people. A group of indigent people and organizations that assisted indigent people with health matters (plaintiffs) sued the Internal Revenue Service (IRS) (defendant) to invalidate the new law. This group presented evidence that hospitals that were tax-exempt under the new law were turning away people who could not pay and argued that these hospitals should not be considered charities. The case ended up before the United States Court of Appeals for the District of Columbia Circuit.

Rule of Law


Holding and Reasoning (Jameson, J.)

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