Illinois Appellate Court
Civil Court
Health Care Services Lien Act
Hospital filed liens against Plaintiff's then yet-to-be-determined personal injury settlement pursuant to Health Care Services Lien Act for full amount of 3 bills for treatment for injuries from auto accident. Court properly dismissed Plaintiff's complaint against hospital under Consumer Fraud Act, breach of contract, "3rd-party beneficiary", and unjust enrichment. Lien Act permits hospital to place liens on all of Plaintiff's claims and causes of action for amount of hospital bills. When a 3rd-party tortfeasor is involved, provider may seek payment from the 3rd party first. Terms of Agreement between hospital and health insurer make clear that Plaintiff was not a 3rd-party beneficiary of Agreement. (TURNER and APPLETON, concurring.)