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Wheaton v. Department of Public Aid
Citations: 416 N.E.2d 780; 92 Ill. App. 3d 1084; 48 Ill. Dec. 507; 1981 Ill. App. LEXIS 2044Docket: 79-98
Court: Appellate Court of Illinois; February 5, 1981; Illinois; State Appellate Court
In the case Richard Wheaton v. The Department of Public Aid, the Illinois Appellate Court affirmed a lower court's ruling regarding liens on Wheaton's settlement from an automobile accident. Wheaton, injured in the accident, settled for the maximum insurance payout of $10,000. He incurred medical expenses totaling over $5,000, of which he received $1,300 in assistance from the Illinois Department of Public Aid. The Department, the Swedish American Hospital, Canfield Clinic, and Rockford Anesthesiologists filed liens against his settlement for their respective medical charges. While the trial court reduced the Department's lien to $50, it upheld the full amounts of the hospital and physicians' liens. Wheaton appealed, arguing that the 'fund' doctrine, established in Baier v. State Farm Insurance Co., should apply to the hospital and physicians' liens, allowing him to claim credit for attorney fees from the settlement. However, the Illinois Supreme Court’s ruling in Maynard v. Parker clarified that the 'fund' doctrine does not entitle a hospital with a lien to contribute to attorney fees related to personal injury claims. The court distinguished this situation from Baier, emphasizing the specific nature of hospital liens as separate from the contractual arrangements in that case. The Maynard court established that a plaintiff's obligation to a hospital arises from the services rendered, making the plaintiff a debtor regardless of any created fund. This ruling is applied to hospital liens, affirming that the trial court correctly rejected the 'fund' doctrine in this context. The same rationale extends to physicians' liens, leading to a refusal to apply the 'fund' doctrine to the liens from the Clinic and Rockford. The court also dismissed the petitioner's argument regarding the authority to reduce the hospital and physicians' liens. The Illinois hospital and physicians' liens acts state that hospitals and physicians have liens on claims related to injured persons, limited to one-third of the total settlement amount. The adjudication of these liens does not empower the trial court to reduce them if the total does not exceed one-third. The court referenced O'Donnell v. Sears, Roebuck & Co. to clarify that the hospital liens act lacks provisions for court-ordered reductions, contrasting it with the Public Aid Code, which allows such discretion. The trial court correctly affirmed the hospital's lien of $2,366.67, which did not exceed one-third of a $10,000 settlement, as well as the combined amounts of physicians' liens, confirming the lack of authority for reductions. The order of the Circuit Court of Winnebago County is thus affirmed.