City of Arvada ex rel. Arvada Police Department, Petitioners v. Denver Health and Hospital Authority, Respondent

Summary

The court held that the treatment-while-in-custody statute does not create a private right of action allowing a hospital to recover treatment costs from a police department. It applied the same implied-private-right-of-action framework to governmental and private defendants and concluded that the statute neither creates a duty to healthcare providers nor shows legislative intent to authorize their claims. The court nevertheless held that Denver Health's unjust-enrichment claim could proceed and was not barred by governmental immunity, requiring further proceedings on that claim. Justice Gabriel concurred while urging legislative clarification, and Justice Coats concurred in part but would have ordered judgment for Arvada and rejected the unjust-enrichment claim.