Truman Medical Center, Inc. v. American Standard Insurance Company Charles Fanning
2017 Mo. App. LEXIS 39
| Mo. Ct. App. | 2017Background
- On Nov. 19, 2013 Charles Fanning was injured in an auto accident; he was treated at Truman Medical and incurred $4,347.02 in bills.
- Fanning provided Truman Medical the insurer and claim number for the at-fault driver but could not recall the driver’s name.
- Truman Medical sent a hospital lien notice to American Standard on Nov. 25, 2013 stating the identity of the tortfeasor was "unknown" but including the insurer’s claim number.
- American Standard received the notice, accessed the claim file using the claim number, evaluated Fanning’s claim, and later settled with Fanning for $25,000 without paying the hospital lien.
- Truman Medical sued under Mo. Rev. Stat. § 430.250 to enforce its lien; both parties moved for summary judgment on stipulated facts.
- The trial court granted summary judgment to Truman Medical; the appeals court affirmed, holding the claim number sufficiently identified the tortfeasor under § 430.240.
Issues
| Issue | Truman Medical's Argument | American Standard's Argument | Held |
|---|---|---|---|
| Whether § 430.240 requires the lien notice to include the tortfeasor’s name (and whether a claim number suffices) | A strict textual reading requiring a name is impractical; where the tortfeasor is unknown, providing available identifiers (e.g., claim number) satisfies the statute | The statute’s plain language requires naming the person alleged to be liable; omission renders the lien invalid | The claim number, which allowed American Standard to identify the tortfeasor, satisfied § 430.240’s identification requirement; lien valid |
| Whether Truman Medical had to supplement the lien once the tortfeasor’s identity became known | Not necessary where initial notice identified the claim and insurer | Must supplement to perfect the lien | Court did not reach this issue as the first issue was dispositive |
Key Cases Cited
- ITT Commercial Fin. Corp. v. Mid-Am. Marine Supply Corp., 854 S.W.2d 371 (Mo. banc 1993) (summary judgment review is de novo)
- Ivie v. Smith, 439 S.W.3d 189 (Mo. banc 2014) (statutory interpretation reviewed de novo; plain language controls)
- BASF Corp. v. Dir. of Revenue, 392 S.W.3d 438 (Mo. banc 2012) (statutory ambiguity and intent analysis)
- Dutton v. American Family Mutual Insurance Company, 454 S.W.3d 319 (Mo. banc 2015) (insurance coverage analysis related to vehicle policies)
- Steven v. Residential Funding Corp., 334 S.W.3d 477 (Mo. Ct. App. 2010) (presumption that each statutory word has effect)