Ex Parte University of South Alabama
Ex Parte University of South Alabama
Opinion
We issued the writ of certiorari to review an issue of first impression, the interpretation *Page 242
of Alabama's hospital-lien statute, §
On May 13, 1996, Garrick was readmitted to USA Medical Center.2 She was discharged on May 20. USA Medical Center claims that Garrick incurred $33,857.75 in medical charges during that second admission. The Alabama Medicaid Agency paid none of these charges.
Garrick received a financial settlement based on the injuries she had suffered in the accident. Pursuant to Ala. Code 1975, §
Garrick and USA Medical Center each moved for a summary judgment. The trial court granted Garrick's motion, declaring that "the proposed lien [was] defective in that it violates the requirements of [Ala. Code 1975,] §
The Court of Civil Appeals affirmed the trial court's judgment, concluding that the language of §
"Any person, firm, hospital authority or corporation operating a hospital in this state shall have a lien for all reasonable charges for hospital care, treatment and maintenance of an injured person who entered such hospital within one week after receiving such injuries, upon any and all actions, claims, counterclaims and demands accruing to the person to whom such care, treatment or maintenance was furnished, or accruing to the legal representatives of such person, and upon all judgments, settlements and settlement agreements entered into by virtue thereof on account of injuries giving rise to such actions, claims, counterclaims, demands, judgments, settlements or settlement agreements and which necessitated such hospital care, subject, however, to any attorney's lien."
(Emphasis added.)
USA Medical Center argues that the Court of Civil Appeals' interpretation of §
Both Garrick and USA Medical Center note this principle:
Ex parte State Dep't of Revenue,"The cardinal rule of statutory interpretation is to determine and give effect to the intent of the legislature as manifested in the language of the statute. Gholston v. State,
620 So.2d 719 (Ala. 1993). Absent a clearly expressed legislative intent to the contrary, the language of the statute is conclusive. Words must be given their natural, ordinary, commonly understood meaning, and where plain language is used, the court is bound to interpret that language to mean exactly what it says. IMED Corp. v. Systems Engineering Associates Corp.,602 So.2d 344 (Ala. 1992)."
Section
This Court has recognized that the hospital-lien statute is to be construed broadly in order not to defeat a just hospital claim. Guin v. Carraway Methodist Med. Ctr.,
The Texas Court of Civil Appeals addressed a similar issue inBaylor University Medical Center v. Travelers Insurance Co.,
Id. (Emphasis omitted.) Thus, the Texas court concluded that a hospital was entitled to a lien for the patient's subsequent admissions, provided the patient's initial admission came within 72 hours of the accident.8 Id."The overriding purpose of article 5506a, as amended, is to induce hospitals to receive a patient, injured by the negligence of others, by giving the hospital a lien on the claims, suit or settlement of the patient. The inducement is for `immediate' (within seventy-two hours) reception of the patient. The inducement is co-extensive with the `treatment, care and maintenance as may have been given to injured persons.' The inducement extends alike to the `admitting hospital and to any hospital to which injured persons may be transferred.' The inducement secures the first administered treatment and `subsequent treatments of the same injuries for which he was originally admitted.'"
The purpose of Alabama's hospital-lien statute and this Court's recognition that the statute is to be construed broadly to accomplish its purpose compel the conclusion that §
Because Garrick's initial admission to the hospital came within one week of the injury, USA Medical Center is entitled to a lien for all reasonable charges incurred by the patient during that admission and during the subsequent admission, provided USA Medical Center proves the other requirements of the hospital-lien statute. Accordingly, we reverse the judgment of the Court of Civil Appeals and remand this case for further proceedings consistent with this opinion.10
REVERSED AND REMANDED.
Hooper, C.J., and Maddox, Houston, Cook, Lyons, Brown, Johnstone, and England, JJ., concur.
"1. On or about the 8th or 9th of April, 1996, [Garrick] was injured in an automobile accident in Clarke County, Alabama.
". . . .
"3. [Garrick] received hospital care, treatment and maintenance for the injuries which [she] received in the automobile accident through May 20, 1996."
"Section 1. Every association, individual, corporation, or other institution maintaining a hospital or clinic rendering hospital services in the State of Texas shall be entitled to a lien upon any and all rights of action, suits, claims, counter claims, or demands of any persons admitted to any hospital and receiving treatment, care, and maintenance therein, on account of any personal injuries received in any accident as the result of the alleged negligence of any other person or firm or corporation or joint stock association, his, its, or their agent, servant or employee, which any such injured person may or shall have, assert, or maintain against any such other person or firm or corporation or joint stock association for damages on account of such injuries, for the amount of the charges of such hospital or clinic for such treatment, care and maintenance as may have been given to the injured persons. Provided the lien provided for herein shall not exist or attach unless the injured person is received in a hospital within seventy-two (72) hours after the happening of the accident causing the injury, in which case both the admitting hospital and any hospital to which such injured person may be transferred from the admitting hospital for subsequent treatments of the same injuries for which he was originally admitted shall be entitled to such lien."
"(a) A hospital has a lien on a cause of action or claim of an individual who receives hospital services for injuries caused by an accident that is attributed to the negligence of another person. For the lien to attach, the individual must be admitted to a hospital not later than 72 hours after the accident.
"(b) The lien extends to both the admitting hospital and a hospital to which the individual is transferred for treatment of the same injury."
Moreover, the doctrine of expressio unius est exclusioalterius is subject to certain exceptions:
Sutherland Stat. Constr. § 47.25 (5th ed. 1992 Supp. 1999)."[T]he maxim will be disregarded and an expanded meaning given where an expanded interpretation will accomplish beneficial results, where [application of the maxim] would thwart the legislative intent made apparent by the entire act, [or where the expanded meaning would] serve the purpose for which the statute was enacted, is a necessary incidental to a power or right, or [reflects] the established custom, usage or practice."
Reference
- Full Case Name
- Ex Parte University of South Alabama D/B/A the University of South Alabama Medical Center. (Re: University of South Alabama, D/B/A the University of South Alabama Medical Center v. Angela Garrick).
- Cited By
- 18 cases
- Status
- Published