Missouri Court of Appeals, Southern District / Feb 19, 2020
ROSE FORD, Respondent vs. SKAGGS CHIROPRACTIC, LLC, Appellant
Rose Ford, injured in a car crash, received treatment from Skaggs Chiropractic, LLC, and signed an "Assignment & UCC Lien" purporting to waive statutory limits on medical liens. After Ford settled her personal injury claim, the trial court applied Missouri's medical lien statutes to determine the amount owed to Skaggs, limiting its recovery. The appellate court affirmed, holding that the medical lien statutes provide the exclusive remedy for healthcare providers seeking payment from personal injury settlements, superseding any contractual agreements. The court also found Skaggs failed to preserve its argument regarding insufficient evidence of attorney's fees.