Morgan v. Saint Luke’s Hosp. of Kan. City (Summary)

LIEN ON PATIENT TORT CLAIM

Morgan v. Saint Luke’s Hosp. of Kan. City, No. WD 75098 (Mo. Ct. App. June 28, 2013)

The Missouri Court of Appeals ruled that a patient’s debt had been extinguished because of the presence of a contract between the hospital and the patient’s health insurance provider, which works to compel the participation of the hospital in accepting discounted payments from the patient’s health insurance provider that serve to extinguish the underlying patient account – in this case, the patient’s debt. The court reasoned that a lien cannot exist in the absence of a debt; thus, the patient’s pleadings stated a cause of action so as to survive a motion for judgment on the pleadings.