The Board of Trustees of the University of Alabama for its Division, University Hospital v. Carolyn Todd

CourtCourt of Civil Appeals of Alabama
DecidedSeptember 26, 2025
DocketCL-2025-0234
StatusPublished

This text of The Board of Trustees of the University of Alabama for its Division, University Hospital v. Carolyn Todd (The Board of Trustees of the University of Alabama for its Division, University Hospital v. Carolyn Todd) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Board of Trustees of the University of Alabama for its Division, University Hospital v. Carolyn Todd, (Ala. Ct. App. 2025).

Opinion

Rel: September 26, 2025

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS SPECIAL TERM, 2025 _________________________

CL-2025-0234 _________________________

The Board of Trustees of the University of Alabama for its Division, University Hospital

v.

Carolyn Todd

Appeal from Jefferson Circuit Court (CV-21-900578)

PER CURIAM.

The Board of Trustees of the University of Alabama for its Division,

University Hospital ("UAB Hospital"), appeals from a judgment of the

Jefferson Circuit Court ("the trial court") that, among other things,

directed the clerk of the trial court to disburse $7,570 of interpleaded CL-2025-0234

money to Carolyn Todd. Todd had interpleaded the money to cover a

hospital lien that UAB Hospital had filed against her for the amount it

had charged her for treatment she had received at its facility for injuries

she said she had suffered in a fall. The trial court also dismissed Todd's

second amended complaint against UAB Hospital in its entirety on the

ground that UAB Hospital was entitled to State immunity from the tort

claims that Todd had asserted against it. This appeal does not involve

the dismissal of the tort claims. For the reasons discussed herein, we

reverse the judgment and remand the case to the trial court for further

proceedings.

Background

This matter began in February 2021 when Todd commenced in the

trial court a personal-injury action against a grocery store where she had

fallen in June 2020. In her complaint against the grocery store, Todd

alleged that she had incurred an unspecified amount of medical expenses

when she was treated for injuries that she said she had suffered in the

fall. In October 2020, UAB Hospital filed a hospital lien against Todd in

the amount of $7,570, which it asserted were the reasonable and

necessary charges arising out of the treatment Todd had received at its

2 CL-2025-0234

facility. UAB Hospital was not named as a party in Todd's original

complaint.

On April 1, 2024, after receiving leave of court, Todd filed her first

amended complaint adding UAB Hospital as a defendant. In the first

amended complaint, Todd averred that she had reached a settlement of

$30,000 from the grocery store in the underlying personal-injury action.

She claimed that UAB Hospital had a hospital lien in place that attached

to her settlement of that action. She sought an interpleader hearing and

asked the trial court to determine the reasonableness, relatedness, and

necessity of the medical charges secured by the hospital lien. She also

asked the trial court to determine whether the lien was valid or, in the

alternative, to determine the fair and reasonable amount UAB Hospital

was owed for its services and asked permission to interplead the amount

of the hospital lien.

Todd also asked the trial court to declare whether, under § 35-11-

370, Ala. Code 1975, UAB Hospital was a "person, firm, hospital

authority, or corporation" authorized to place liens upon third-party

financial recoveries for injuries. Todd also alleged a claim of unjust

enrichment and claims asserting violations of her constitutional rights to

3 CL-2025-0234

equal protection and due process. She also sought to enjoin UAB Hospital

from charging her for what she says are unreasonably high medical bills

and to compel UAB Hospital to amend or withdraw the lien. On April 8,

2024, the trial court entered an order dismissing the grocery store as a

defendant. On May 13, 2024, the UAB formally appeared in the case. On

July 3, 2024, again with leave of the trial court, Todd filed a second

amended complaint adding numerous tort claims against UAB Hospital

and Thomas Elmes, in his official capacity as the manager of patient

financial services for UAB Hospital.

On August 12, 2024, UAB Hospital filed a motion to dismiss Todd's

second amended complaint in its entirety on the ground that, as an agent

of the state, UAB Hospital and its agent, Elmes, were entitled to

sovereign immunity, also known as State immunity, under § 14 of the

Alabama Constitution of 2022, which provides that "the State of Alabama

shall never be made a defendant in any court of law or equity." It also

argued that, in his individual capacity, Elmes was entitled to State-agent

immunity.

In the motion to dismiss, UAB Hospital observed that the lien was

a "net lien" that automatically encumbered any recovery Todd obtained

4 CL-2025-0234

and that only liens for attorney fees would take priority over the hospital

lien. It argued that the only claim against it and Elmes that Todd had

alleged in the second amended complaint over which the trial court "could

possibly obtain jurisdiction" was the claim for interpleader relief, adding:

"However, in its current state, the [trial c]ourt does not have jurisdiction

and the claim is due to be dismissed as a matter of law." (Emphasis in

original.) UAB Hospital explained that Todd had "coupled with her

interpleader claim an additional request for the [trial] court to 'determine

the reasonableness, relatedness and necessity of the medical treatment' "

she had received and to order a reduction in the amount of the hospital

lien. That request, UAB hospital said, suggested that Todd was seeking

the trial court's review of the hospital lien, which, it said, is authorized

under § 35-11-373, Ala. Code 1975.

However, citing Roberts v. University of Alabama Hospital, 27 So.

3d 512, 514 n.1 (Ala. Civ. App. 2008), and Board of Trustees of University

of Alabama v. Richards, 405 So. 3d 267 (Ala. Civ. App. 2024), UAB

Hospital argued in the motion that, for the trial court to obtain

jurisdiction over the claim for interpleader relief, three things had to

occur: (1) the settlement money had to be interpleaded with the trial

5 CL-2025-0234

court, (2) UAB Hospital had to be added as a party to the action, and (3)

the judgment determining the amount of the lien must be entered after

the settlement and dismissal of the underlying tort claims. Because Todd

had not yet interpleaded the settlement money into the trial court, UAB

Hospital argued, the trial court lacked custody, control, and supervision

of that money and thus had not obtained subject-matter jurisdiction, that

is, it had not yet obtained in rem jurisdiction over the settlement money.

Therefore, UAB Hospital concluded, the claim for interpleader relief was

due to be dismissed as a matter of law.

In response to the motion to dismiss, Todd argued that the

contested settlement money had been held in trust by her attorneys and

that she had "already offered the contested funds for deposit." She

asserted that, under Rule 22(b), Ala. R. Civ. P., which governs

interpleader procedure, depositing money with the clerk of the court is

permissive rather than mandatory and that, therefore, the trial court had

subject-matter jurisdiction over the claim for interpleader relief. She

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