ILCS » Chapter 770 · Act 23
Illinois Compiled Statutes

770 ILCS 23/1 (2026)

Short title

✓ current as of May 2026
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(770 ILCS 23/1)
    Sec. 1. Short title. This Act may be cited as the Health Care Services Lien Act.
(Source: P.A. 93-51, eff. 7-1-03.)

    
Notes of Decisions
Cited in 25 cases (4 in the last 5 years), 2004–2026 · leading case: Manago v. The Cnty. of Cook, 2017 IL 121078 (Ill. 2017).
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Manago v. The Cnty. of Cook, 2017 IL 121078 (Ill. 2017). · cites it 3× “The public hospital that treated the minor obtained a health care lien on any damage recovery pursuant to the Health Care Services Lien Act (Lien Act) ( 770 ILCS 23/1 et seq. (West 2012)). On the minor's motion, the trial court extinguished the hospital's lien.”
Wendling v. S. Illinois Hosp. Servs., 950 N.E.2d 646 (Ill. 2011). · cites it 2× “The hospitals who treated the plaintiffs asserted liens against the proceeds of the lawsuits, pursuant to the Health Care Services Lien Act (770 ILCS 23/1 et seq. (West 2008)). The circuit court of Williamson County held, based on the “common fund doctrine,” that the…”
Manago v. The Cnty. of Cook, 2016 IL App (1st) 121365 (Ill. App. Ct. 2016). “OPINION ¶1 Respondent the County of Cook (County) appeals an order entered by the circuit court of Cook County striking, dismissing, and extinguishing a hospital lien arising under the Health Care Services Lien Act (Act) (770 ILCS 23/1 et seq. (West 2004)) for services rendered…”
Manago v. Cnty. of Cook, 2017 IL 121078 (Ill. 2018). · cites it 3× “The public hospital that treated the minor obtained a health care lien on any damage recovery pursuant to the Health Care Services Lien Act (Lien Act) (770 ILCS 23/1 et seq. (West 2012)). On the minor’s motion, the trial court extinguished the hospital’s lien.”
Constantinou v. Global Fin. Credit, LLC, 2021 IL App (1st) 192325 (Ill. App. Ct. 2021). “Constantinou also sought “a judgment declaring Defendants committed deceptive, unfair and illegal acts, were negligent and engaged in negligent misrepresentation, and violated 770 ILCS 23/1, 23/10(b) [notice requirements], and 23/10(e) [direct payment requirement], et seq.”
McVey v. M.L.K. Enter., LLC, 2015 IL 118143 (Ill. 2015). “In the case of a claim, demand, or cause of action with respect to which the total amount of all liens under the Health Care Services Lien Act [770 ILCS 23/1 et seq.] meets or exceeds 40% of the sum paid or due the injured person, the total amount of all liens under this…”
Barry v. St. Mary's Hosp. Decatur, 2016 IL App (4th) 150961 (Ill. App. Ct. 2017). “Mary’s filed liens against Barry’s then yet-to-be-determined personal injury settlement pursuant to the Health Care Services Lien Act (Lien Act) (770 ILCS 23/1 to 999 (West 2012)) for the full, i.”
Lopez v. Morley, 817 N.E.2d 592 (Ill. App. Ct. 2004). “Even so, section 35 of the Health Care Services Lien Act (770 ILCS 23/35 (West 2002)) provides: "A lien validly created under * * * the Hospital Lien Act * * * remains in full force and effect on and after July 1, 2003. Such a lien shall be enforceable according to, and…”
McVey v. M.L.K. Enter., LLC, 2015 IL 118143 (Ill. 2015). “In the case of a claim, demand, or cause of action with respect to which the total amount of all liens under the Health Care Services Lien Act [770 ILCS 23/1 et seq.] meets or exceeds 40% of the sum paid or due the injured person, the total amount of all liens under this…”
Barry v. St. Mary's Hosp. Decatur, 2016 IL App (4th) 150961 (Ill. App. Ct. 2016). “Mary’s filed liens against Barry’s then yet-to-be-determined personal injury settlement pursuant to the Health Care Services Lien Act (Lien Act) (770 ILCS 23/1 to 999 (West 2012)) for the full, i.”
Wolf v. Toolie, 2014 IL App (1st) 132243 (Ill. App. Ct. 2014). “The County of Cook (Cook County) filed liens against plaintiffs for unpaid medical bills on behalf of the hospital, pursuant to the Health Care Services Lien Act (Act) (770 ILCS 23/1 et seq. (West 2012)). Subsequently, each plaintiff filed a lawsuit against the other parties…”
McKim v. S. Illinois Hosp. Servs., 2016 IL App (5th) 140405 (Ill. App. Ct. 2016). · cites it 2× “Herrin Hospital contends that the trial court improperly included Medicare, Medicare Part D, and Medicaid “liens” in the total amount of liens subject to the 40% cap mandated by the Health Care Services Lien Act (770 ILCS 23/1 et seq. (West 2012)). Because the court allowed 100%…”
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