Shelby Cnty. Health Care Corp v. So. Farm Bureau Cas. Ins. Co.

Smiley, a resident of Monroe County, Arkansas, was severely injured when a vehicle driven by Medford, a resident of Woodruff County, struck Smiley’s vehicle. The accident occurred in Monroe County. Smiley was transported to the Med, a medical center in Memphis, Tennessee, where he received care before dying from his injuries. Under the Tennessee Hospital Lien Act, the Med filed a lien for the unpaid balance of over $355,000 in Tennessee and mailed copies to the attorneys for Smiley’s estate. After negotiating with Medford’s insurer, the administratrix for Smiley’s estate petitioned the probate court to authorize a settlement of $700,000. That court noted that no medical liens had been filed in Monroe County and that the Med’s lien was void and unenforceable in Arkansas as the Med did not follow the requirements of the Arkansas Medical, Nursing, Hospital, and Ambulance Service Lien Act. None of the settlement proceeds were paid to the Med, which filed suit in federal court, claiming impairment of its hospital lien. The court granted summary judgment, concluding that Arkansas law applied and would not permit the Med to recover. The Eighth Circuit vacated. The district court failed to identify the elements of a hospital lien impairment action. Viewed as a claim for damages for lien impairment, significant issues remain unaddressed. View "Shelby Cnty. Health Care Corp v. So. Farm Bureau Cas. Ins. Co." on Justia Law