Yaffee v. Joseph Skeen (2024)
Plaintiff sought treatment for injuries in a hospital emergency room and was discharged that same day. Plaintiff later sought extensive treatment, including two spinal surgeries, at the same hospital. The hospital asserted a lien under the Hospital Lien Act (HLA) (Civ. Code, § 3045.1, et seq.) for the full amount billed for all of plaintiff’s treatment, which was more than plaintiff’s medical insurance company paid for plaintiff’s treatment. At trial, the jury awarded the full amount of the HLA lien.
The Court of Appeal reversed. The court held that under the HLA, a hospital is ordinarily limited to the amount it accepts as payment from the patient’s insurance company absent an agreement with the carrier to the contrary. Although the hospital had such an agreement, the HLA only applies to “emergency services” rendered by the hospital. The Court of Appeal held that “emergency services” end when the patient is discharged by the hospital. Thus, the HLA did not apply to any of the plaintiff’s medical services after he was discharged by the hospital emergency room on the first day he received treatment. The court remanded for a new trial to determine the allowable amount of plaintiff’s recovery under the holdings in Howell v. Hamilton Meats & Provisions, Inc. (2011) 52 Cal.4th 541, 566, and Corenbaum v. Lampkin (2013) 215 Cal.App.4th 1308, 1329, that the plaintiff cannot recover past medical damages exceeding the amount paid by his medical insurance.
