Arizona Supreme Court

Jackie Abbott v. Banner Health Network

May 23, 2016

Summary

The court held that the patients’ agreements with hospitals settling disputed medical liens were valid accord-and-satisfaction agreements, even assuming federal law preempted the Arizona lien statutes. Because the enforceability of the liens was genuinely disputed when the settlements were made, the agreements had both proper subject matter and adequate consideration. The court therefore reversed the court of appeals and affirmed dismissal of the patients’ complaint.