Arizona Supreme Court

Walter Ansley v. Banner Health Network

March 9, 2020248 Ariz. 143

Summary

The court held that Medicaid patients may maintain an equitable private action to challenge hospital liens used to recover amounts exceeding Medicaid reimbursement. It further held that the Arizona lien statutes are preempted, and therefore unconstitutional as applied, when used for such balance billing against third-party tort recoveries. The court rejected the patients' contract-based theory, upheld attorney fees under the private attorney general doctrine, vacated the court of appeals' opinion, and affirmed the trial court's judgment.