Hospital Lien Is Subject To Common Fund Doctrine

June 30, 2010

Wendling v. Woolard; Howell v. Dunaway, Nos. 110199 & 110200 Cons. , 5th District of Illinois, is a case that was decided in March 2010. At issue in this case was whether a hospital’s statutory lien for services rendered to an injured plaintiff, which was filed pursuant to the Health Care Services Lien Act, should be subject to a reduction under the common-fund doctrine for attorney fees incurred by the injured plaintiff.

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