430.230. Hospitals to have liens — when, against whom. — Every public hospital or clinic, and every privately maintained hospital, clinic or other institution for the care of the sick, which is supported in whole or in part by charity, located within the state of Missouri, or any such hospital duly incorporated under the laws of Missouri providing for the incorporation of eleemosynary institutions, shall have a lien upon any and all claims, counterclaims, demands, suits, or rights of action of any person admitted to any hospital, clinic or other institution and receiving treatment, care or maintenance therein for any cause including any personal injury sustained by such person as the result of the negligence or wrongful act of another, which such injured person may have, assert or maintain against the person or persons causing such injury for damages on account of such injury, for the cost of such services, computed at reasonable rates not to exceed twenty-five dollars per day and the reasonable cost of necessary X-ray, laboratory, operating room and medication service, as such hospital, clinic, or other institution shall render such injured person on account of his conditions; provided further, that the lien herein set forth shall not be applied or considered valid against anyone coming under the workers' compensation law in this state.
Notes of Decisions
Kelly v. Marvin's Midtown Chiropractic, LLC, 351 S.W.3d 833 (Mo. Ct. App. 2011).
· cites it 166× “It provides, in pertinent part: Every public hospital or clinic, and every privately maintained hospital, clinic or other institution for the care of the sick, which is supported in whole or in part by charity, located within the state of Missouri, or any such hospital duly…”
Am. Fam. Mut. Ins. Co. v. Ward, 774 S.W.2d 135 (Mo. 1989).
· cites it 14× “230, in pertinent part, provides qualified hospitals: shall have a lien upon any and all claims, counterclaims, demands, suits, or rights of action of any person admitted to any hospital, clinic or other institution and receiving treatment, care or maintenance therein for any…”
Morgan v. Saint Luke's Hosp. of Kansas City, 403 S.W.3d 115 (Mo. Ct. App. 2013).
· cites it 22× “Luke’s because such actions were within its legal right under section 430.230, and (3) Ms. Morgan did not plead facts sufficient to show it would be unjust for St.”
Schoedinger v. Beck, 557 S.W.3d 531 (Mo. Ct. App. 2018).
· cites it 5× “Section 430.230 specifically established that healthcare providers that render medical services to persons injured as the result of another's negligence or wrongful act shall have a lien on any and all claims the injured person may assert against the persons or persons who…”
Frankum v. Hensley, 884 S.W.2d 688 (Mo. Ct. App. 1994).
· cites it 9× “Since the hospital offered no evidence that its charges were for necessary services as required for an effective lien under both sections 430.230 and 430.235, ... the hospital failed to meet its burden of proof on an essential element of its hospital lien claim.”
Boley v. Knowles, 905 S.W.2d 86 (Mo. 1995).
· cites it 2× “§ 430.230, RSMo 1994. Similarly, federal law, under certain circumstances, may operate to allow hospitals to file and enforce a lien for services provided upon a personal injury award of a minor.”
Beckett v. Dep't of Soc. Servs., 948 S.W.2d 250 (Mo. Ct. App. 1997).
· cites it 15× “The Hen statute reHed on by Hospital, Section 430.230 RSMo 1994 1 , provides in relevant part: Every pubHc hospital or clinic, and every privately maintained hospital, clinic or other institution for the care of the sick, which is supported in whole or in part by charity,…”
Truman Med. Ctr., Inc. v. Am. Stand. Ins. Co. Charles Fanning, 508 S.W.3d 122 (Mo. Ct. App. 2017).
· cites it 2× “Section 430.230 provides, in relevant part: Every public hospital or clinic, and every privately maintained hospital, clinic or other institution for the care of the sick, which is supported in whole or in part by charity, located within the state of Missouri .”
Huey v. Meek, 419 S.W.3d 875 (Mo. Ct. App. 2013).
· cites it 3× “See §§ 430.230, 430.225.3. The statute was “designed with a dual purpose: to ensure that injured patients are quickly treated without first considering if the patients are able to pay and to protect health care providers financially so that they could continue to provide care.”
Truman Med. Centers, Inc. v. John E. McKay, 505 S.W.3d 799 (Mo. Ct. App. 2016).
· cites it 2× “Section 430.230 provides, in relevant part: • *802 Every public hospital or clinic, and every privately maintained hospital, clinic or other institution for the care of the sick, which is supported in whole or in part by charity, located within the state of Missouri .”
Skaggs Chiropractic, L.L.C. v. Ford, 564 S.W.3d 633 (Mo. Ct. App. 2018).
“Other institutions "have the same rights granted to hospitals in sections 430.230 to 430.250." Section 430.”
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