Manago v. County of Cook

Illinois Appellate Court
Civil Court
Case Number: 
2013 IL App (1st) 121365
Decision Date: 
August 30, 2013
1st Dist.
Cook Co., 6th Div.
Reversed and remanded.
(Court opinion corrected 9/4/13.) Court erred in entering order striking, dismissing, and extinguishing hospital lien arising under Health Care Services Lien Act for services rendered to minor by hospital. Hospital's lien may properly attach to judgment secured by Plaintiff, as lien was not invalidated, and hospital was not required to intervene in personal injury suit to protect its lien. Hospital lien may properly attach to a recovery by a minor, and may attach to a recovery even where recovery does not contemplate award for medical expenses.(LAMPKIN, concurring; GORDON, dissenting.)