McAllen Hosps., LP v. State Farm County Mut. Ins. Co. (Opinion)
Annotate this CaseTwo Patients were injured in a car accident with Third-Party. Patients were treated at Hospital, and to secure payment, Hospital filed hospital liens under the Hospital Lien Statute. Patients settled with Third-Party and released their claims against him. Third-party’s Insurer made the settlement checks jointly payable to Patients and Hospital. Patients deposited the checks without Hospital’s endorsement, and Hospital was never reimbursed for the treatment costs. Hospital sued Insurer to enforce its hospital liens, but Insurer refused payment, contending that it met its obligation to pay Hospital under the Hospital Lien Statute by making the checks payable to Hospital as a copayee. The trial court granted summary judgment for Insurer, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Hospital’s charges were not “paid” under the Hospital Lien Statute and Uniform Commercial Code; and (2) Hospital’s liens on Patients’ causes of action remained intact.
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