Premier Physicians Group, PLLC v. Navarro

JUSTICE BOLICK,

opinion of the Court:

¶ 1 We granted review to decide when a non-hospital health care provider may perfect a lien to secure its charges. This case turns on the statutory requirement that such a lien must be recorded “before or within thirty days after the patient has received any services relating to the injuries_” A.R.S. § 33-932(A). We hold that the statute requires providers to record their liens within thirty days after first providing services.

I

¶ 2 Between June and October 2011, Premier Physicians Group (“Premier”) treated Mandy Gipson for injuries sustained in a car…