Via Christi Regional Medical Center, Inc. v. Reed
298 Kan. 503
| Kan. | 2013Background
- Reed was severely injured in a car-train collision and received emergency treatment at Via Christi; Via Christi later filed a hospital lien claiming roughly $83,365.64 against Reed’s $540,000 settlement with Union Pacific.
- Reed’s sister signed an admission/assignment form in the hospital (she crossed out one paragraph but left paragraph 4 intact, which stated patient responsibility for balances not covered by insurance).
- Via Christi did not give statutory notice to Union Pacific as required by K.S.A. 65-407 and did not file a claim identifying the railroad; Via Christi also failed to timely obtain public benefits that might have reduced its claim.
- An audit of Via Christi’s itemized bill revealed overcharges, duplicate charges, and some undercharges; Reed alleged these inaccuracies supported claims under the Kansas Consumer Protection Act (KCPA).
- The district court enforced the lien and granted summary judgment to Via Christi on Reed’s KCPA claims; the Court of Appeals affirmed lien enforceability but remanded to determine equitable distribution under K.S.A. 65-406(c). Reed petitioned and the Kansas Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument (Reed) | Defendant's Argument (Via Christi) | Held |
|---|---|---|---|
| Whether a hospital lien can be valid absent an underlying debt | Lien invalid because Reed (via sister’s form) relieved himself of personal liability; lien requires an underlying debt | Hospital argued statute creates independent lien right against recovery even if patient not personally liable | Court: Lien requires an underlying debt; without strict statutory foundation lien is invalid |
| Whether notice requirements of K.S.A. 65-407 can be satisfied by substantial compliance or actual knowledge | Reed: strict statutory notice required; lack of notice to Union Pacific defeats lien | Via Christi: substantial compliance and Union Pacific’s actual knowledge suffice | Court: Strict compliance is required; Via Christi failed to comply, so lien ineffective against Reed |
| Whether Reed is an “aggrieved” consumer under the KCPA | Reed: lien and its supporting (inaccurate) bill materially and economically affected his rights — he is aggrieved | Via Christi: Reed not personally sued or charged; no adverse legal effect so not aggrieved | Court: Reed is aggrieved because the lien encumbered settlement funds and bill contained overcharges creating a concrete injury |
| Whether filing/pursuit of the lien can constitute deceptive or unconscionable KCPA violations | Reed: inaccuracies, duplicate entries, vague descriptions and pursuit of full lien amount support deceptive and unconscionable practices | Via Christi: lien statutes and equitable-distribution mechanism preclude KCPA liability for enforcement of a lien | Court: A hospital may violate KCPA by filing/pursuing a lien based on inaccurate or misleading billing; genuine factual disputes preclude summary judgment and claims must be remanded for trial |
Key Cases Cited
- Miller v. Westport Ins. Corp., 288 Kan. 27 (standard for summary judgment)
- Haz-Mat Response, Inc. v. Certified Waste Servs., Ltd., 259 Kan. 166 (statutory liens require claimants to strictly comply with authorizing statute)
- Boyce v. Knudson, 219 Kan. 357 (liens, statutory nature, and requirement to bring claim within statute's provisions)
- In re Estate of Enloe, 109 Ill. App. 3d 1089 (Ill. App. 1982) (contrasting view that hospital lien can be treated independently of common-law contract debt)