Manago v. The County of Cook

Because deceased minor's parent did not assign her cause of action for medical expenses to the injured minor plaintiff, the County does not have a lien under the Health Care Services Lien Act. County must go through family expenses statute to recover medical expenses incurred by Plaintiff. Section 10(a) of Health Care Services Lien Act provides health care providers with a lien, and describes nature of claim triggering creation of the lien, i.e., claims for reasonable medical charges.  (GORDON, specially concurring; LAMPKIN, dissenting.)