Premier Physicians Group, PLLC v. Navarro

OPINION

NORRIS, Judge:

¶ 1 Under Arizona Revised Statutes (“AR.S.”) section 33-932 (2014), a health care provider, other than a hospital, may perfect a medical lien if it records the lien “before or within thirty days after the patient has received any services relating to the injuries.” We hold this provision allows a non-hospital health care provider to perfect a lien retroactively for any services received by the provider’s patient within the 30 days preceding the provider’s recording of the lien and prospectively thereafter, assuming the *157provider complies with all other statutory lien…