ROSE FORD v. SKAGGS CHIROPRACTIC, LLC

Citation: Not availableDocket: SD36080

Court: Missouri Court of Appeals; February 18, 2020; Missouri; State Appellate Court

Original Court Document: View Document

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Rose Ford filed a lawsuit against the driver of another vehicle after being injured in a car crash in August 2013, seeking treatment from Skaggs Chiropractic, LLC. Ford signed a UCC Lien agreement that assigned her rights to medical expense proceeds from any potential claims, including those from insurance or other payers, directly to Skaggs. This agreement aimed to establish Skaggs as the primary lienholder for her treatment costs, including a waiver of any statutory limits on the distribution of settlement proceeds that might affect Skaggs' claim. 

Skaggs later filed a notice of its UCC lien with the Missouri Secretary of State. After Ford reached a $7,500 settlement, she filed a motion in court to determine the medical liens held by Skaggs and other providers, which included participation from Skaggs' attorney. The trial court ruled that the medical lien statutes provided an exclusive remedy for health care providers and determined that Skaggs was owed $2,083.66. The trial court's judgment was affirmed on appeal, finding no merit in Skaggs' arguments against the application of Missouri's medical lien statutes.

In a bench-tried civil case, the judgment will be upheld unless it lacks substantial evidence, is contrary to the weight of the evidence, or misapplies the law, as established in Murphy v. Carron. This standard applies universally to court-tried cases, with legal conclusions reviewed independently without deference to the trial court. In the case at hand, Skaggs contends that the trial court incorrectly assessed the lien amount, arguing that Ford waived the benefits of the hospital lien and that Missouri's medical lien statutes do not pertain to Skaggs' UCC lien. Skaggs' initial appeal was dismissed due to an incomplete judgment regarding Ford's claim against Bridwell. Following a small claims action against Ford, which was dismissed but later led to a trial de novo, the court found that overlapping issues triggered the abatement doctrine. The trial court issued a final judgment on March 14, 2019, prompting this appeal. Missouri's medical lien statutes create a limited exception to the prohibition on assigning personal injury claims, allowing certain medical providers, including chiropractors since 2003, to secure liens for the cost of care provided. The case of Huey, involving a similar lien situation, affirmed that the statutory remedy under section 430.225 is exclusive and supersedes common law remedies. The exclusivity of these statutes was further upheld in Schoedinger v. Beck, outlining the procedures health care providers must follow to recover amounts for services rendered to injured parties.

The Court determined that Skaggs' guaranty was overridden by statute, specifically § 430.225, which limits healthcare providers to collecting no more than 50% of a settlement amount for lien satisfaction. This statute, as interpreted in Huey and Schoedinger cases, establishes the exclusive remedy for healthcare providers asserting a lien on settlement proceeds. Skaggs’ intention to claim a lien on Ford's settlement necessitated the application of § 430.225, which invalidates any agreements attempting to secure a lien for the full cost of medical services outside the medical lien statute. Missouri law holds that contracts violating statutes are unenforceable. 

In addressing Skaggs' challenge regarding the sufficiency of evidence for the enforceable lien amount, the Court noted that Skaggs did not raise the issue of attorney's fees during the trial or file any post-judgment motions prior to appeal. Citing precedents, the Court emphasized that issues must be presented to the trial court to be preserved for appellate review. Consequently, Skaggs failed to preserve this claim, leading to the denial of Point 2. The trial court's judgment was ultimately affirmed.