Columbus Regional Hospital v. Federal Emergency Management Agency

Dist. Ct. did not err in granting defendant’s motion for summary judgment in action alleging that defendant improperly failed to award plaintiff $20 million in additional disaster relief under Stafford Act. While plaintiff alleged that additional award was warranted because defendant was required to cover replacement cost of damaged hospital equipment, as opposed to cost of said equipment less depreciation, defendant could properly determine that depreciated cost is appropriate measure of loss in absence of any statute requiring defendant to award relief based on replacement cost. Ct. rejected plaintiff’s argument that replacement cost was required since: (1) medical regulators required that plaintiff replace damaged equipment with new equipment; and (2) one of defendant’s employees promised reimbursement for cost of new equipment.