Constantinou v. Global Financial Credit, LLC

Plaintiff alleged that a healthcare provider, from whom Plaintiff received medical treatment after a personal injury (PI), attempted to assign its statutory lien against the Plaintiff's PI settlement to a billing company. Plaintiff adequately alleged that Defendants' improper use of the lien procedure deprived her of a right she would otherwise have enjoyed. Plaintiff's request for a declaration that, in attempting to assign the lien, Defendants violated section 10(e) of the Health Care Services Lien Act and for injunction prohibiting them from asserting existence of a valid lien were proper requests for equitable relief. (HARRIS and O. JOHNSON, concurring.)