Dollieslager v. Hurst

Does the Physicians Lien Act (Act) (770 ILCS 80/0.01 et seq. (West 1996)) require that a physician be able to demonstrate a causal connection between an underlying event and the services he rendered before his lien can attach to funds related to a patient’s tort action? We hold that it does. Therefore, we vacate and remand.

FACTS

Plaintiff Kimberly Dollieslager was first treated by defendant Michael Hurst, a chiropractor, in November 1989 for headaches, cervical pain, pain between her shoulders, stiffness of the neck, and numbness in her arms. These symptoms arose sometime in September 1989 and…