A. In order to perfect a lien granted by section 33-931, the executive officer, licensed health care provider or agent of a health care provider shall record, before or within thirty days after the patient has received any services relating to the injuries, except a hospital which shall record within thirty days after the patient is discharged, in the office of the recorder in the county in which the health care provider is located a verified statement in writing setting forth all of the following:
1. The name and address of the patient as they appear on the records of the health care provider.
2. The name and location of the health care provider.
3. The name and address of the executive officer or agent of the health care provider, if any.
4. The dates or range of dates of services received by the patient from the health care provider.
5. The amount claimed due for health care.
6. For health care providers other than hospitals or ambulance services, to the best of the claimant's knowledge, the names and addresses of all persons, firms or corporations and their insurance carriers claimed by the injured person or the injured person's representative to be liable for damages arising from the injuries for which the person received health care.
B. The verified statement shall also include the amount claimed due as of the date of recording of the claim or lien and a statement regarding whether the patient's treatment has been terminated or will be continued. Amounts incurred during the continued period are also subject to the lien.
C. The claimant shall also mail, by first class mail within five days after recording the claim or lien, a copy of the claim or lien to the injured person. For health care providers other than hospitals or ambulance services the claimant shall also mail a copy to all persons, firms or corporations and their insurance carriers claimed by the injured person or the injured person's representative to be liable for damages arising from the injuries for which the person received health care. If a health care provider other than a hospital or ambulance service does not record the claim, lien or assignment as provided in this section, the claim, lien or assignment is invalid and may not be enforced by the cause of action provided in section 33-934. If a hospital records such a claim or lien, the recording shall be notice to all persons, firms or corporations liable for damages, whether or not they are named in the claim or lien.
D. A hospital or ambulance service lien that is not recorded within the time prescribed by this section is effective against any settlement or judgment for damages if the lien is recorded thirty days before the settlement is agreed to or the judgment is paid except if the lien is recorded in a county where liens are accessible on the internet, the lien is effective if the lien is accessible on the internet thirty days or more before the settlement is agreed to or the judgment is paid. If the lien is not recorded or is not accessible on the internet as provided in this section, the lien is invalid and may not be enforced by the cause of action provided in section 33-934.
Notes of Decisions
Premier Physicians Grp., PLLC v. Navarro, 377 P.3d 988 (Ariz. 2016).
· cites it 17× “These liens are perfected by recording pursuant to A.R.S. § 33-932. On September 16, 2011, Premier recorded a lien to secure payment of approximately $12,000 for its services.”
Blankenbaker v. Jonovich, 71 P.3d 910 (Ariz. 2003).
· cites it 20× “§ 33-934 requires, as a prerequisite to such an enforcement action, that the lien be perfected in accordance with A.R.S. § 33-932. I. ¶ 2 Petitioner Tommy Jonovieh was injured in an automobile accident.”
Andrews v. Samaritan Health Sys., 36 P.3d 57 (Ariz. Ct. App. 2001).
· cites it 12× “It is undisputed that the medical hens were all untimely recorded under A.R.S. § 33-932, the hen perfection statute.”
Maricopa Cnty. v. Barfield, 75 P.3d 714 (Ariz. Ct. App. 2003).
· cites it 5× “¶4 On July 30, 1998, pursuant to A.R.S. § 33-932, Maricopa County recorded a health care provider lien for the full amount of Jenkins’s medical charges.”
Honorhealth v. abboud/weinstein (Ariz. Ct. App. 2026).
· cites it 154× “¶24 The statute’s plain language reinforces that the two subparts of A.R.S. § 33-932, (A) and (B), are separate and contain different requirements that serve different purposes.”
LaBombard v. Samaritan Health Sys., 991 P.2d 246 (Ariz. Ct. App. 1998).
“A.R.S. 33-932 (1990). The verified statement must provide certain specific information, and the hospital must send a copy of the lien by certified mail to the injured person.”
Blankenbaker v. Jonovich, 52 P.3d 795 (Ariz. Ct. App. 2002).
· cites it 7× “In Andrews , we held that a hospital which had untimely recorded its lien pursuant to A.R.S. § 33-932 held an unperfected but enforceable lien.”
Premier Physicians Grp., PLLC v. Navarro, 357 P.3d 840 (Ariz. Ct. App. 2015).
· cites it 15× “The Navarros moved to dismiss Premier’s complaint arguing that by waiting until September 16, 2011 to record its lien, Premier had failed to perfect the lien within 30 days after it had provided “any services” to the third party as required by A.R.S. § 33-932. The superior court…”
Midtown Med. Grp., Inc. v. Farmers Ins. Grp., 334 P.3d 1252 (Ariz. Ct. App. 2014).
“Specifically, if the injured patient settles his or her claim without paying the health care lienholder or obtaining a release, the provider can enforce its perfected lien in an action against the tortfeasor “or against any insurer or other person, firm or corporation that is…”
Berrey v. Inv. Funding, LLC, 96 F. Supp. 3d 936 (D. Ariz. 2015).
· cites it 13× “Perfecting Health Care Provider Liens The Arizona Supreme Court has held that for a health care provider lien to be enforceable, it must be filed with the county recorder in accordance with the perfection provision of Ariz.Rev.Stat. § 33-932. Blankenbaker, 71 P.”
Ansley v. Banner Health, 419 P.3d 552 (Ariz. Ct. App. 2018).
· cites it 2× “" It requires that when a hospital has treated an AHCCCS member for an injury "reflecting the probable liability of a first- or third-party," the hospital must, within 30 days of discharging the patient, notify AHCCCS "under R9-22-1008" or mail the agency "a copy of the lien the…”
— Ariz. Rev. Stat. § 33-932(A) — 3 cases
Premier Physicians Grp., PLLC v. Navarro, 377 P.3d 988 (Ariz. 2016).
“These liens are perfected by recording pursuant to A.R.S. § 33-932. On September 16, 2011, Premier recorded a lien to secure payment of approximately $12,000 for its services.”
Honorhealth v. abboud/weinstein (Ariz. Ct. App. 2026).
“¶24 The statute’s plain language reinforces that the two subparts of A.R.S. § 33-932, (A) and (B), are separate and contain different requirements that serve different purposes.”
Berrey v. Inv. Funding, LLC, 96 F. Supp. 3d 936 (D. Ariz. 2015).
“Perfecting Health Care Provider Liens The Arizona Supreme Court has held that for a health care provider lien to be enforceable, it must be filed with the county recorder in accordance with the perfection provision of Ariz.Rev.Stat. § 33-932. Blankenbaker, 71 P.”
— Ariz. Rev. Stat. § 33-932(A)(4) — 1 case
Honorhealth v. abboud/weinstein (Ariz. Ct. App. 2026).
“¶24 The statute’s plain language reinforces that the two subparts of A.R.S. § 33-932, (A) and (B), are separate and contain different requirements that serve different purposes.”
— Ariz. Rev. Stat. § 33-932(A)(6) — 1 case
Premier Physicians Grp., PLLC v. Navarro, 377 P.3d 988 (Ariz. 2016).
“These liens are perfected by recording pursuant to A.R.S. § 33-932. On September 16, 2011, Premier recorded a lien to secure payment of approximately $12,000 for its services.”
— Ariz. Rev. Stat. § 33-932(B) — 3 cases
Premier Physicians Grp., PLLC v. Navarro, 377 P.3d 988 (Ariz. 2016).
“These liens are perfected by recording pursuant to A.R.S. § 33-932. On September 16, 2011, Premier recorded a lien to secure payment of approximately $12,000 for its services.”
Honorhealth v. abboud/weinstein (Ariz. Ct. App. 2026).
“¶24 The statute’s plain language reinforces that the two subparts of A.R.S. § 33-932, (A) and (B), are separate and contain different requirements that serve different purposes.”
Berrey v. Inv. Funding, LLC, 96 F. Supp. 3d 936 (D. Ariz. 2015).
“Perfecting Health Care Provider Liens The Arizona Supreme Court has held that for a health care provider lien to be enforceable, it must be filed with the county recorder in accordance with the perfection provision of Ariz.Rev.Stat. § 33-932. Blankenbaker, 71 P.”
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