Court: Court of Civil Appeals of Alabama; May 26, 1995; Alabama; State Appellate Court
On March 22, 1993, Trussell V. Johnson was injured in a motor vehicle accident and subsequently received treatment at Huntsville Hospital from April 12 to April 14, 1993, incurring a bill of $7,778.67, which he disputed as unreasonable. In May 1993, the Hospital filed a lien for this amount. Johnson filed a complaint for interpleader in October 1993, questioning the reasonableness of the Hospital's charges and seeking a determination on the distribution of settlement proceeds from the at-fault driver's insurance. The Hospital claimed entitlement to the full billed amount based on a contractual agreement. Both parties filed motions for summary judgment, with Johnson's motion ultimately denied, leading to a summary judgment in favor of the Hospital for $7,778.67. Johnson appealed, arguing that the Hospital lacked a valid statutory lien since he did not enter the facility within one week of the accident, as required by Ala.Code 1975, § 35-11-870. The Hospital countered that it could recover the reasonable cost of services rendered based on the admissions contract, and the statutory lien was not necessary. The court acknowledged that the statute aimed to provide hospitals a secured creditor status for claims when treatment occurs shortly after an injury. However, the Hospital's lien was filed 20 days post-discharge, raising questions about compliance with the statutory requirements. The court noted that such requirements should be interpreted liberally to avoid undermining legitimate hospital claims.
The injured party did not seek treatment at the Hospital within a week after the accident, nor did the Hospital timely establish a statutory lien under Ala.Code 1975, 35-11-370. As a result, the Hospital's claim to "secured creditor" status is invalid. Johnson acknowledges that the Hospital is entitled to compensation for its services but disputes the validity of the statutory lien. He contends that while the Hospital proved the nursing care was reasonable and necessary, it failed to provide medical evidence of causation. However, Johnson's complaint states that his treatment was related to the accident injuries. The Hospital demonstrated that its charges were reasonable and customary, with Johnson providing no evidence to counter this claim. Previous case law supports the Hospital's position, affirming summary judgment when the Hospital substantiates its charges and the patient fails to present conflicting evidence. The trial court found that the Hospital was entitled to the charged amount for its services based on the contract with Johnson, leading to the affirmation of the summary judgment.
