In a significant ruling for auto injury claims, the Georgia Court of Appeals has decided in favor of a hospital seeking payment from Progressive Mountain Insurance Company. This case centers around a minor, Elizabeth Giles, who was injured in a car accident and received treatment at AU Medical Center. The court’s decision highlights an important aspect of Georgia law regarding hospital liens.
The incident began when Giles, then a minor, was hurt while riding in a car insured by Progressive. After her treatment at AU Medical Center, the hospital filed a lien to secure payment for the medical services provided. A lien is a legal claim that allows the hospital to seek payment from any future compensation related to the injuries.
After more than a year, Giles settled her claims with Progressive’s insured and signed a release. However, the hospital’s lien remained unpaid. This prompted AU Medical Center to sue Progressive to recover its costs. In response, Progressive filed a complaint against Giles, claiming she had agreed to cover any liens in her settlement.
As the case progressed, all three parties—AU Medical Center, Progressive, and Giles—requested summary judgment. The trial court ruled in favor of the hospital, leading Progressive to appeal the decision.
On April 30, 2025, the Georgia Court of Appeals upheld the trial court’s ruling. The court rejected Progressive’s argument that, since Giles was a minor, she wasn’t legally responsible for the medical bill, making the lien unenforceable. The judges clarified that under Georgia law, the hospital’s lien is tied to the patient’s personal injury claim, not the patient’s personal liability for the debt.
Progressive attempted to reference a previous case from 1997 that dealt with insurance reimbursement for minors. However, the court pointed out that this case was not relevant to hospital liens and involved different legal standards. The judges emphasized that Georgia’s lien statute does not require the injured person to owe the medical bill for the lien to be valid.
This ruling reinforces that hospitals in Georgia can enforce their liens against injury settlements, even when the injured party is a minor. It serves as a crucial reminder for insurance companies, particularly those handling auto policies in Georgia, to be vigilant about outstanding hospital liens when settling injury claims. The decision shows that while a patient may not be legally obligated to pay a bill, it does not eliminate the hospital’s right to collect through a lien.
The court’s ruling came from a panel of judges, including Judges McFadden, Hodges, and Pipkin. They did not disclose the names of the attorneys involved in the case. For those managing injury settlements in Georgia, this case underscores the importance of recognizing and addressing hospital liens, especially in situations involving minors.