Premier Physicians Group v. Navarro (8/30/16)

We blogged the opinion of the Court of Appeals here; go there for the facts.

The Supreme Court vacates that opinion and affirms the trial court’s dismissal of the Complaint. “We hold that [33-932A] requires providers to record their liens within thirty days after first providing services.”

Rather than distinguish the hospital-lien statute the Supreme Court uses it as a guide: “Given the clear triggering event established for hospitals [viz., the receipt of “any services”], it would be anomalous to construe [33-932A’s] language as a rolling rather than fixed deadline without the statute expressly saying so.” Having thus rejected the Court of Appeals’ approach the opinion examines the details of the lien statutes to determine legislative intent and give meaning to all words.

(Opinion: Premier Physicians Group v. Navarro)