Bryner v. Cardon OutreachAnnotate this Case
The Supreme Court affirmed the district court’s interpretation of Utah’s Hospital Lien Statute, Utah Code 38-7-1, holding that the court correctly concluded that the Hospital Lien Statute does not require a hospital to pay its proportional share of an injured person’s attorney fees and costs when a hospital lien is paid due to the efforts of the injured person or that person’s attorney.
Plaintiffs in this proposed class action were all involved in car accidents, received medical care at the healthcare institutions named as defendants in this suit, and filed personal injury claims against the third parties at fault. All had hospital liens placed on any potential recovery from these claims, and all reached settlement agreements. Plaintiffs argued that Defendants failed to pay their fair share of the attorney fees Plaintiffs incurred in generating the settlement proceeds. The district court granted summary judgment to Defendants. The Supreme Court affirmed, holding that the plain language of the Hospital Lien Statute creates a priority for the distribution of the proceeds in third-party liability cases and that Plaintiffs’ proportional sharing arguments were unavailing.