Parnell v. Adventist Health System/West

Opinion

BROWN, J.

Under the Hospital Lien Act (HLA; Civ. Code, §§ 3045.1-3045.6), 1 a hospital that treats a patient injured by a third party tortfeasor may assert a lien against any judgment, settlement, or compromise recovered by that patient from the tortfeasor in the amount of its “reasonable and necessary charges” (§ 3045.1). In this case, a hospital received payment from a patient and his health insurer and agreed to accept that payment as “payment in full” for its services. Nonetheless, the hospital asserted a lien under the HLA, seeking to recover the difference between its usual and…