California Court of Appeal
Dameron Hospital Assn. v. AAA Northern California, Nevada and Utah Ins. Exchange, C070475
In this action brought by plaintiff-hospital to recover on its Hospital Lien Act (HLA) liens, summary judgment in favor of defendant automobile insurers on grounds that the patients' debts and already been fully satisfied by their healthcare service plans is affirmed, where: 1) the contract between plaintiff and defendants does not contain the term described by the court in Parnell v. Adventist Health System/West as sufficient to preserve the right to recover the customary billing rate for emergency room services from third party tortfeasors; and 2) a history of voluntary cooperation does not suffice to avail plaintiff of the Parnell court's guidance on reservation of contractual rights under the HLA.
Appellate Information
- Decided 09/04/2014
- Published 09/04/2014
Judges
- Hoch
Court
- California Court of Appeal