This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A chiropractor provided medical treatment to a worker injured in a workplace accident. The worker and his attorney signed a "Doctor's Lien," assigning a portion of any settlement proceeds to the chiropractor for unpaid medical services. The attorney later received a $5,000 settlement but, following the worker's instructions, paid the entire amount to the worker, disregarding the lien.
Procedural History
- Metropolitan Court: Granted summary judgment in favor of the attorney, finding no enforceable obligation under the lien.
- District Court: Reversed the Metropolitan Court's decision and remanded the case for a hearing on the merits.
Parties' Submissions
- Plaintiff (Chiropractor): Argued that the "Doctor's Lien" constituted a valid assignment of settlement proceeds, obligating the attorney to pay the assigned amount. Claimed that consideration for the lien included continued medical treatment, provision of medical information, and forbearance from immediate collection of fees.
- Defendant (Attorney): Asserted that the lien was void for lack of consideration and illegal under the Workers' Compensation Act, which exempts compensation benefits from creditor claims.
Legal Issues
- Was the "Doctor's Lien" a valid and enforceable assignment of settlement proceeds?
- Did the lien lack consideration, rendering it unenforceable?
- Was the lien illegal under the Workers' Compensation Act?
Disposition
- The Supreme Court of New Mexico affirmed the District Court's decision, holding that the lien was enforceable and remanded the case to the Metropolitan Court for further proceedings.
Reasons
Per Ransom J. (Baca and Franchini JJ. concurring):
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Validity of Assignment: The "Doctor's Lien" was a valid assignment of the worker's right to settlement proceeds. The attorney, as obligor, was obligated to honor the assignment and pay the chiropractor. The worker's unilateral revocation of the assignment did not discharge the attorney's duty to the assignee.
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Consideration: The chiropractor provided sufficient evidence of consideration, including continued treatment, provision of medical information, and forbearance from immediate collection of fees. These raised genuine issues of material fact, precluding summary judgment on this ground.
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Illegality: The Workers' Compensation Act exempts benefits from creditor claims but does not preclude voluntary assignments. The lien was not an attempt to garnish or attach benefits but rather an agreement between the worker and the chiropractor. The attorney became obligated to the assignee upon accepting the assignment.
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Attorney Fees: The chiropractor's request for attorney fees on appeal was denied due to the absence of statutory authority, but costs on appeal were awarded.