Manago v. The County of Cook

Minor plaintiff was injured while riding on roof of an elevator owned by Chicago Housing Authority. Public hospital that treated him obtained health care lien on any recovery pursuant to Health Care Services Lien Act. In the absence of a parental assignment, a statutory health care lien may attach to a minor's tort recovery where that recovery does not explicitly include expenses for the minor's medical care and treatment. Creditors may seek a remedy under Family Expense Act and/or Lien Act in the appropriate case. Application of Lien Act is not limited by age of injured plaintiff or Family Expense Act's parental liability provision. (KARMEIER, FREEMAN, THOMAS, GARMAN, BURKE, and THEIS, concurring.)