Lee Memorial Health System v. Progressive Select Insurance

Summary

The Court affirmed the determination that the LMHS Lien Law is unconstitutional because it is a special law concerning the creation, enforcement, extension, or impairment of liens based on private contracts. It held that the underlying hospital-services agreement is private because its subject matter involves individualized medical services and payment from private assets, regardless of the public status of the hospital. The Court also held that the lower appellate court should not have reached the contract-impairment issue because the required constitutional notice was not timely served, and it declined to address the statutory-damages issue.