Dade County v. Pavon’s Empirical Analysis
1972
Citation profile
5 state decisions
How this case has been cited
Cited by 6 later decisions — most recently September 2012
5 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on 222 So. 2d 254 - Allison v. Imperial Casualty and Indemnity Co. · 218 So. 2d 793 - Palm Springs Gen. Hosp., Inc. v. State Farm Mutual Automobile Insurance Company · Rutkin v. State Farm Mutual Automobile Ins. Co. · State Farm Mutual Automobile Insurance v. Palm Springs General Hospital, Inc. of Hialeah
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Every hospital operator] shall be entitled to a lien for all reasonable charges for hospital care, treatment and maintenance of ill or injured persons upon any and all causes of action, suits, claims, counterclaims and demands accruing to the persons to whom such care, treatment or maintenance are furnished or accruing to the legal representatives of such persons, and upon all judgments, settlements and settlement agreements rendered or entered into by virtue thereof, on account of illness or injuries giving rise to such causes of action, suits, claims, counterclaims, demands, judgment, settlement or settlement agreement and which necessitated or shall have necessitated such hospital care, treatment and maintenance.”
2 later decisions quote this exact passage““For example, the lien provided for in §1 of the statute is for all reasonable charges for hospital care, etc. Also, in §4 it is provided that a satisfaction of judgment or a settlement will not be effectual against such a lien unless the lienholder joins therein and executes a release of the lien, and further, that acceptance of such a release or satisfaction, in the absence of a release of the lien, shall be regarded prima facie as an impairment of such lien, for which the lienholder is given a right of action against the one accepting such settlement release or judgment satisfaction for ‘the reasonable cost of such hospital care, treatment and maintenance,’ plus attorney fees and costs.” (Emphasis in text.) "If the lien of a hospital as provided for in the statute was not meant to be effective for its full amount (subject to a right to question the propriety of the charges comprising the same), it would not be reasonable or consistent for the statute to authorize recovery of the full amount of the hospital's (lien) charges against one who', without the hospital lien having been released, should receive a satisfaction of jjudgment or a release upon settlement. Conversely, since the statute allows a hospital lienor full recovery in the situation outlined above, it would be illogical to conclude that such a hospital lien should not be applied in full against proceeds of a judgment or settlement.” (Emphasis added.)”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.