Action Chiropractic Clinic, LLC v. Prentice Delon Hyler, 467 S.W.3d 409

On Oct. 24, 2011 Hyler was injured in an auto accident and received chiropractic treatment from Action Chiropractic Clinic (clinic), incurring $5,010 in fees.
On Oct. 31, 2011 Hyler signed an "Assignment of Rights" purporting to assign to the clinic "medical expense benefits allowable, and otherwise payable to me under the current Insurance Policy," naming Erie Insurance (Erie) as the policyholder.
Erie insured the other driver (Burnette); Erie received a copy of the assignment on Jan. 18, 2012.
On Mar. 1, 2012 Erie settled with Hyler for $8,510 and sent Hyler a check with a letter stating Erie does not pay medical providers directly. Hyler executed a general release.
The clinic demanded payment from Erie; receiving none, it sued Hyler and Erie for unpaid services. The trial court granted Erie summary judgment; the Court of Appeals affirmed. The Tennessee Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hyler’s "Assignment of Rights" validly assigned to the clinic proceeds from Hyler’s claim against Erie	The assignment was a valid direct assignment of benefits/rights to the clinic, entitling it to payment from Erie	The document did not assign proceeds of a claim against Erie; it purported to assign only Hyler’s own insurance benefits and thus was ineffective as to Erie	The assignment was ineffective; it did not clearly assign settlement/proceeds from Hyler’s claim against Erie, so summary judgment for Erie was proper

Parker v. Holiday Hospitality Franchising, Inc., 446 S.W.3d 341 (Tenn. 2014) (standard of review for summary judgment)
West v. Shelby Cnty. Healthcare Corp., 459 S.W.3d 33 (Tenn. 2014) (contract interpretation principles)
Byrd v. Hall, 847 S.W.2d 208 (Tenn. 1993) (definition of material factual dispute)
Alaimo Family Chiropractic v. Allstate Ins. Co., 574 S.E.2d 496 (N.C. Ct. App. 2002) (contrast where assignment language did transfer claim proceeds)
Seymour v. Sierra, 98 S.W.3d 164 (Tenn. Ct. App. 2002) (Tennessee not a direct-action state for suing liability insurer)
Bob Pearsall Motors v. Regal Chrysler-Plymouth, Inc., 521 S.W.2d 578 (Tenn. 1975) (contract language construed in plain, ordinary sense)
Maggart v. Almany Realtors, Inc., 259 S.W.3d 700 (Tenn. 2008) (when contract language is clear, literal meaning governs)