SKAGGS CHIROPRACTIC, L.L.C., Plaintiff- Missouri Cases

Skaggs Chiropractic, L.L.C. (Provider) appealed a judgment in a small-claims case that denied its claim for chiropractic services rendered to Rose Ford (Patient). The trial court declined to enter judgment for Provider, finding its UCC lien superseded by the medical lien statute and that its decision would be inconsistent with a prior interlocutory ruling in Patient's separate personal injury suit. The appellate court reversed and remanded, holding that the prior ruling was not a final judgment and thus did not trigger collateral estoppel, but that the abatement doctrine applied due to the overlap between the two cases.