Geico General Insurance v. Hospital Authority, 319 Ga. App. 741

Hospitals filed three hospital liens totaling $66,999.22 against Kunz for care after a March 2010 car accident with Geico-insureds.
Kunz settled her underlying action with the Kalishes in September 2010 for $100,000; settlement documents were signed October 8, 2010, and required lien satisfaction from the settlement funds.
The settlement contained a general release from all claims, but the liens were not satisfied.
Hospitals learned of the settlement in June 2011 and sued Geico to enforce the liens on October 6, 2011.
Geico moved for summary judgment, asserting the action was time-barred under OCGA § 44-14-473(a)'s one-year deadline after the liability was finally determined.
Trial court denied the motion; on interlocutory appeal, the court reversed, holding the action was time-barred and the lien could not be enforced.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does the one-year deadline start?	Hospitals: deadline begins at the release.	Geico: deadline begins at the settlement.	Deadline starts at settlement; time-barred.
Do letters memorializing a verbal settlement satisfy 'settlement' for triggering the clock?	Yes, letters memorialize a settlement.	No, a formal release is required.	Yes; letters can evidence a final settlement triggering the clock.

Matjoulis v. Integon Gen. Ins. Corp., 226 Ga. App. 459 (1997) (recognizes settlement/release concepts under timing)
Herring v. Dunning, 213 Ga. App. 695 (1994) (settlement defined; release implications on liability)
Integon Indem. Corp. v. Henry Med. Center, 235 Ga. App. 97 (1998) (liability avoidance by settlement and release; lien implications)
Six Flags Over Ga. II v. Hull, 276 Ga. 210 (2003) (statutory timing interpretation principles)
Aimwell, Inc. v. McLendon Enterprises, 318 Ga. App. 394 (2012) (interpretation and application of timing provisions)
Boyd v. JohnGalt Holdings, LLC, 318 Ga. App. 866 (2012) (statutory construction principles applied to timing)