Baylor University Medical Center v. Annabell Borders

This appeal involves the construction of Tex.Rev.Civ.Stat.Ann. art. 5506a (Vernon 1975), commonly referred to as the Hospital Lien Statute. Appellant Baylor Medical University Center filed a hospital lien in accordance with the statute against the account of Sabrina Borders, a minor. The trial court held that Baylors claim was barred by limitations. We hold, however, that the statute establishes a separate cause of action independent of the patients obligation to pay the bill and that the hospitals cause of action accrues only when judgment or settlement proceeds are actually paid, rather than when the patient becomes obligated to pay the hospital bill. Thus, Baylors claim was not barred by the statute of limitations. Accordingly, we reverse and render.