Portercare Adventist Health System v. Lego, 286 P.3d 525

Porter admitted Lego’s wife to Porter’s emergency room on August 14, 2001; Mrs. Lego stayed until November 9, 2001.
Insurance notified Lego in late Sept. 2001 that coverage would stop after Oct. 10, 2001; Lego refused discharge and accepted responsibility disputes.
Porter notified Lego in writing that liability would shift after Oct. 10, 2001; an oral notice of financial responsibility followed on Oct. 24, 2001.
Porter billed Lego $144,044.86 on November 24, 2001 for expenses after Oct. 10, 2001; Lego refused to pay.
Porter filed suit for money owed on April 28, 2005; Lego argued the action was for unjust enrichment/quantum meruit and subject to a three-year limit.
Trial court and then the court of appeals disagreed about whether the debt was a liquidated debt and which statute of limitations applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does six-year limit apply to liquidated debt in hospital context?	Porter contends debt is liquidated under 18-80-108.5(1)(a).	Lego argues debt is not liquidated, triggering three-year limit.	Yes; six-year limit applies to liquidated debt in hospital context.
Does § 13-80-103.5(1)(a) require a written contract or formula to be liquidated?	Liquidated debt may be determined by extrinsic computation, not only written terms.	Only debts matching a stated amount or formula are liquidated.	Debt can be liquidated by reference to the agreement or by simple computation using extrinsic evidence.

Rotenberg v. Richards, 899 P.2d 365 (Colo. App. 1995) (defines liquidated debt; supports computation-based ascertainment)
Uhl v. Fox, 498 P.2d 1177 (Colo. App. 1972) (example of liquidated debt when price proof depends on extrinsic data)
Larson v. American National Bank, 484 P.2d 1230 (Colo. 1971) (implied in fact contract lacking price term; quantum meruit considerations)