Premier Physicians Group, PLLC v. NavarroAnnotate this Case
Premier Physicians Group, a non-hospital health care provider, treated Mandy Gipson for injuries sustained in a car accident allegedly caused by Kimberly Navarro. Premier was statutorily entitled to record a lien for its customary charges in treating Gipson, and the lien applied to claims Gipson may have had for damages related to her injury. Ariz. Rev. Stat. 33-932(A) requires that such liens must be recorded “before or within thirty days after the patient has received any services relating to the injuries….” The Navarros’ insurer paid Gipson to settle her claim but did not satisfy the lien, and Gipson failed to pay Premier for its services. Premier sued the Navarros to enforce the lien. The trial court dismissed the complaint because the lien was recorded more than thirty days after Premier first provided services to Gipson. Premier appealed, arguing that section 33-932() allowed it to perfect with lien within thirty days after services were last provided. The court of appeals agreed with Premier and reversed. The Supreme Court vacated the court of appeals’ opinion and affirmed the trial court’s dismissal of the complaint, holding that section 33-932(A) requires non-hospital providers to record liens before services are first provided or within thirty days thereafter.