The Alabama Supreme Court affirmed on Friday the dismissal of a lawsuit initially dismissed in Jefferson County over the size of a lien placed on Lanell Puckett for the medical care she received in UAB Hospital for injuries suffered in a car accident.
According to the Alabama Supreme Court, Puckett was “severely injured” in a car accident and received treatment for her injuries at UAB Hospital in January 2022. Two weeks later, UAB Hospital, owned and operated by the University of Alabama Board of Trustees, filed a hospital lien for $176,685.16 for charges related to Puckett’s treatment. Hospitals may assert a lien for “reasonable charges of hospital care” against any settlement or recovery a patient might receive due to her injuries. Puckett eventually recovered $117,666.17 from her and the other driver’s insurance companies through a settlement.
However, Puckett and UAB Hospital could not reach an agreement as to the amount of the hospital lien and the settlement proceeds were deposited in a trust account belonging to Puckett’s attorney pending resolution of the lien dispute.
On February 2023, Puckett filed a complaint in Jefferson County Circuit Court asking, among other things, for the court to determine the reasonableness, relatedness, and necessity of the medical charges and the validity of the lien as to UAB Hospital.” On June 2023, the University of Alabama Board of Trustees moved to dismiss the complaint, arguing state entities have immunity. The complaint was dismissed in circuit court in December 2023, and the dismissal was affirmed without an opinion by the Alabama Supreme Court on Friday.
The decision was affirmed by Associate Justices Will Sellers, Greg Shaw, Kelli Wise, Brady Mendheim, and Jay Mitchell. Chief Justice Tom Parker and Associate Justices Tommy Bryan, Greg Cook, and Sarah Stewart dissented.
Cook said in his dissenting opinion, “Given the unsettled questions of law raised by this appeal and the curious litigation strategy adopted by the Board, I would have afforded the parties an opportunity to fully explain their actions at oral argument before adjudicating Puckett’s appeal.”
“Nevertheless, based on my review of the parties’ briefs, the record, and the relevant law, I respectfully dissent from this Court’s affirmance of the judgment dismissing Puckett’s complaint. Because the Board commenced a statutory action to perfect and enforce its lien on Puckett’s property…Puckett’s subsequent objections to that lien were asserted defensively with regard to a claim asserted by the State – not a claim against the State,” Cook wrote in his opinion.
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