The Tennessee Supreme Court has determined that a Nashville chiropractic clinic’s patient did not effectively assign his rights to insurance proceeds received from a third party’s insurance company.
The case stems from a 2011 automobile accident that injured defendant Prentice Delon Hyler. Action Chiropractic Clinic in Nashville treated Mr. Hyler for injuries sustained in the accident.
At the clinic, Mr. Hyler signed a document titled “Assignment of Rights,” stating that the clinic would be the beneficiary of, among other things, “medical expense benefits allowable” by various insurance policies. Mr. Hyler incurred $5,010 in clinic fees.
Mr. Hyler subsequently received $8,510 from the Erie Insurance Exchange, which insured the other party involved in the auto accident. Mr. Hyler did not have a policy with Erie Insurance. Erie Insurance refused to honor the “Assignment of Rights” and pay the clinic, and Mr. Hyler did not pay the bill for chiropractic services. The clinic sued Mr. Hyler and Erie Insurance for payment.
Defendant Erie Insurance moved for summary judgment, a decision based on law and made by the courts without a full trial. It is appropriate when there is no dispute over the facts of the case. The trial court in this case granted summary judgment to Defendant Erie, and Action Chiropractic appealed. The Court of Appeals agreed with the trial court, affirming the grant of summary judgment.
The Supreme Court agreed to hear the case and concluded that the document Mr. Hyler signed did not clearly assign the insurance proceeds to Action Chiropractic. In an opinion written by Justice Jeffrey S. Bivins, the Court pointed out that the agreement’s language implies that Mr. Hyler intended to assign proceeds from his own insurance policies, not proceeds from another person’s insurance.
To read the Action Chiropractic Clinic v. Prentice Delon Hyler opinion, authored by Justice Bivins, go to the opinions section of TNCourts.gov.