K.A.L. v. Southern Medical Business Services
Court of Civil Appeals of Alabama
854 So.2d 106 (2003)
K.A.L. attempted suicide by hanging and was found by jail employees, who began resuscitating her before she was admitted comatose to Springhill Memorial Hospital. Hospital staff saved her life over a nine-day stay, but she never paid for the care. The hospital's assignee, Southern Medical Business Services (plaintiff), sued her for the unpaid bill, and the trial court awarded $21,562. K.A.L. appealed, arguing she never consented to treatment because she was unconscious the entire time, and that there was no evidence of any implied contract between her and the hospital.
Whether the doctrine of quasi-contract allows a healthcare provider to enforce an implied contract for medical services against a patient who never expressly consented to treatment.