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Bowden v. The Medical Ctr. Inc.

Where the subject matter of a lawsuit includes the validity and amount of a hospital lien for the reasonable charges for a patient's care, how much the hospital charged other patients, insured or uninsured, for the same type of care during the same time period is relevant for discovery purposes, and the Court of Appeals erred in holding otherwise.

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Georgia law gives a hospital a lien for the reasonable charges for its care and treatment of an injured person against all causes of action accruing to that person on account of her injuries, and establishes a process for the hospital to perfect its lien for the amount claimed to be due. See OCGA §§ 44-14-470, 44-14-471. The Medical Center, Inc. TMC provided hospital care to Danielle Bowden, who did not have health insurance, after she was injured in a car wreck, billed her $21,409.59 for her care, and filed a hospital lien for that amount. In a subsequent lawsuit, Bowden sought to invalidate the lien on the ground that the billed charges were grossly excessive and did not reflect the reasonable value of the care she received, while TMC alleged that $21,409.59 was a reasonable amount for Bowden’s care and sought a declaratory judgment establishing the validity of its lien.

During discovery, TMC objected to Bowden’s requests for, among other things, information and documents regarding the amounts that the hospital charged insured patients for the same type of care. Bowden filed a motion to compel discovery, which the trial court granted subject to the entry of a protective order to ensure confidentiality. On interlocutory appeal, the Court of Appeals reversed, holding that the trial court abused its discretion in granting the motion because “the discovery Bowden seeks is not relevant to her claim that TMC’s medical charges for her treatment were unreasonable.” The Medical Center, Inc. v. Bowden, 327 Ga. App. 714, 714 761 SE2d 116 2014. We granted Bowden’s petition for certiorari to review that holding.

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