Shelby County Health Care Corp. v. Southern Farm Bureau Casualty, No. 15-3765 (8th Cir. 2017)
Annotate this CaseThe court vacated the dismissal of The Med's claim of alleged impairment of a hospital lien, concluding that the claim was not barred by the Rooker-Feldman doctrine. The court explained that to apply Rooker-Feldman in this case to a non-party who had an opportunity to intervene in state-court proceedings would echo the pre- Exxon Mobil Corp. v. Saudi Basic Indus. Corp. lower-court rulings that expanded the doctrine too far. Here, the Med did not seek to reverse the order of the Arkansas state court, and acknowledged that it could not seek a judgment directly against the proceeds of the personal injury settlement. The court also concluded that the district court erred by alternatively ruling that Arkansas law applied to the dispute between the parties. Rather, the court applied a choice-of-law analysis and concluded that Tennessee law applied in this case.
Court Description: Colloton, Author, with Melloy and Shepherd, Circuit Judges] Civil case - Hospital lien. For the court's prior opinion in the matter, see Shelby Cty. Health Care Corp. v. S. Farm Bureau Cas. Ins. Co., 798 F.3d 686 (8th Cir. 2015). Plaintiff brought this claim against the defendants who had settled a wrongful death claim without assigning any of the recovery to pay the medical expenses the deceased incurred with plaintiff; held,the district court erred in finding the claim for impairment of plaintiff's lien was barred by the Rooker-Feldman doctrine; the court erred in finding Arkansas courts would apply Arkansas law under its choice-of-law rules, as Tennessee law applies to this action seeking relief for impairment of a lien; reversed and remanded for further proceedings. Judge Shepherd, dissenting.
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