Sandpoint Convalescent Services v. Idaho

Appellant Sandpoint Convalescent Services, Inc. (Sandpoint Manor) purchased its health care facility from D.J. Convalescent Care, Inc., on June 30, 1983, for about 1.1 million dollars. Prior to that time the owner was reimbursed by the Department of Health and Welfare (DHW) for depreciation due to the wear and tear on the facility resulting from services provided to Medicaid recipients. Idaho Code § 56-104 provides that when such a facility is sold, the previously authorized depreciation is to be recaptured. Sandpoint Manor contends that because the statute requires that the recaptured depreciation be paid by the buyer rather than the seller, it violates substantive due process. We agree with the district Judge that no constitutional infirmity is presented and therefore affirm.