ILCS » Chapter 770 · Act 23
Illinois Compiled Statutes

770 ILCS 23/20 (2026)

Items to which lien attaches

✓ current as of May 2026
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(770 ILCS 23/20)
    Sec. 20. Items to which lien attaches. The lien of a health care professional or health care provider under this Act shall, from and after the time of the service of the lien notice, attach to any verdict, judgment, award, settlement, or compromise secured by or on behalf of the injured person. If the verdict, judgment, award, settlement, or compromise is to be paid over time by means of an annuity or otherwise, any lien under this Act shall be satisfied by the party obligated to compensate the injured person to the fullest extent permitted by Section 10 before the establishment of the annuity or other extended payment mechanism.
(Source: P.A. 93-51, eff. 7-1-03.)

    
Notes of Decisions
Cited in 9 cases, 2007–2018 · leading case: Manago v. The Cnty. of Cook, 2016 IL App (1st) 121365 (Ill. App. Ct. 2016).
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Manago v. The Cnty. of Cook, 2016 IL App (1st) 121365 (Ill. App. Ct. 2016). · cites it 4× “” 770 ILCS 23/20 (West 2004). Consequently, under the Act, “[o]nly when a recovery is made can the lien come into existence, because absent a provision to the contrary, a lien is 7 In fact, the parties stipulated to the medical bills at trial, but not whether the bills were…”
Manago v. The Cnty. of Cook, 2017 IL 121078 (Ill. 2017). “" 770 ILCS 23/20 (West 2012). Finally, the relevant portion of the Family Expense Act provides that "[t]he expenses of the family and of the education of the children shall be chargeable upon the property of both husband and wife, or of either of them, in favor of creditors…”
Progressive Universal Ins. v. Taylor, 874 N.E.2d 910 (Ill. App. Ct. 2007). “” 770 ILCS 23/20 (West 2004). The term “settlement” includes a “[pjayment, satisfaction, or final adjustment.”
Manago v. Cnty. of Cook, 2017 IL 121078 (Ill. 2018). “” 770 ILCS 23/20 (West 2012). Finally, the relevant portion of the Family Expense Act provides that “[t]he expenses of the family and of the education of the children shall be chargeable upon the property of both husband and wife, or of either of them, in favor of creditors…”
Manago v. Cnty. of Cook, 2013 IL App (1st) 121365 (Ill. App. Ct. 2013). · cites it 5× “" 770 ILCS 23/20 (West 2004). Thus, under the Act, "[o]nly when a recovery is made can the lien come into existence, because absent a provision to the contrary, a lien is created only when there is property on hand to which it may attach.”
Howell v. Dunaway, 924 N.E.2d 1190 (Ill. App. Ct. 2010). · cites it 2× “770 ILCS 23/20 (West 2008). On the petition of any interested party, the circuit court shall adjudicate the rights of all the interested parties and enforce the lien.”
Howell v. Dunaway (Ill. App. Ct. 2010). · cites it 2× “770 ILCS 23/20 (West 2008). On the petition of any interested party, the circuit court shall adjudicate the rights of all the interested parties and enforce the lien.”
Progressive Universal Ins. Co. v. Taylor (Ill. App. Ct. 2007). “" 770 ILCS 23/20 (West 2004). The term "settlement" includes a "[p]ayment, satisfac- tion, or final adjustment.”
McRoberts v. Porter, 2013 IL App (5th) 120017 (Ill. App. Ct. 2013). “770 ILCS 23/20 (West 2008). The word “settlement” is defined to include a “[p]ayment, satisfaction, or final adjustment.”
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