Vivek Bedi v. Premium Healthcare Solutions LLC

CourtCourt of Appeals for the Seventh Circuit
DecidedFebruary 3, 2026
Docket25-1419
StatusPublished
AuthorBrennan

This text of Vivek Bedi v. Premium Healthcare Solutions LLC (Vivek Bedi v. Premium Healthcare Solutions LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vivek Bedi v. Premium Healthcare Solutions LLC, (7th Cir. 2026).

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1419 MEDLEGAL SOLUTIONS, INC., doing business as Atticus Medi- cal Billing, Plaintiff-Appellee,

v.

PREMIUM HEALTHCARE SOLUTIONS, LLC, Defendant,

APPEAL OF: VIVEK BEDI.

____________________

Appeal from the United States District Court for the Northern District of Illinois, Eastern Division. No. 1:24-cv-00463 — Jorge L. Alonso, Judge. ____________________

ARGUED NOVEMBER 12, 2025 — DECIDED FEBRUARY 3, 2026 ____________________

Before BRENNAN, Chief Judge, and ST. EVE and KIRSCH, Cir- cuit Judges. BRENNAN, Chief Judge. In this case two judgment creditors compete for the same assets. An individual, Vivek Bedi, se- cured a money judgment in state court against Premier 2 No. 25-1419

Healthcare Solutions, LLC. Years later, a company, MedLegal Solutions, Inc., secured a money judgment in federal court against Premium Healthcare Solutions, LLC. Their collection efforts collided. When Bedi intervened in MedLegal’s post-judgment proceedings, he discovered that his judgment was incorrectly against Premier, not Premium. So he sought and received an order in state court to correct the misnomer. Although this corrective order was entered af- ter MedLegal obtained its judgment, the state court made it effective as of Bedi’s original judgment entered years before. Concerned that the corrective order would unfairly prejudice its claim to Premium’s assets, MedLegal sought an order deeming its secured interest superior to any interest Bedi might have. The district court granted MedLegal’s request. Before evaluating the merits of that ruling on priority, two jurisdictional questions must be addressed: whether the dis- trict court entered a final order on which appellate jurisdic- tion may rest, and whether the Rooker-Feldman doctrine bars the district court from ruling against Bedi on priority. We con- clude that appellate jurisdiction is secure and Rooker-Feldman is no bar. On the merits, we affirm the district court’s holding that MedLegal’s secured interest is superior to Bedi’s pur- ported interest. I. Background The judgment debtor in both cases, Premium Healthcare Solutions, LLC, is a limited liability company in Illinois. Rajeev Batra organized Premium to provide medical imaging services to personal injury and workman compensation claimants. To ensure payment, Premium often obtained health care liens against those plaintiffs’ recoveries pursuant No. 25-1419 3

to the Illinois Health Care Services Lien Act. 770 ILCS 23/1 et seq. A. Competing Liens and Collection Proceedings 1. Bedi obtains a state court lien on the assets of “Premier.” Over the years, Batra and Premium borrowed money from Vivek Bedi as cash flow needs arose. To secure the debt, the parties executed a promissory note in 2019. When Premium defaulted, Bedi sued Batra and “Premier [sic] Healthcare So- lutions, LLC.” In October 2022, the DuPage County, Illinois, Circuit Court entered a judgment against Batra and “Premier” and in favor of Bedi in the amount of $1,578,000, a sum repre- senting unpaid principal and interest. 1 Based on the October 2022 judgment, Bedi began collec- tion proceedings. The clerk of court issued a citation to dis- cover assets—a court notice, similar to a subpoena, to obtain information about a debtor’s assets available to satisfy a judg- ment. After Batra responded to the citation, the state court entered an order against Batra’s membership interest in “Premier” and a continuing impressed lien—a lien that re- mains in effect until a debt is fully satisfied—against “Prem- ier[‘s] tangible and intangible assets in favor of Bedi. Yet Bedi’s October 2022 judgment and the state court’s subsequent orders contained a misnomer—each referred to “Premier” rather than Premium. Premier Healthcare Solu- tions is a distinct entity unrelated to Batra or Premium. This made Bedi’s lien effectively undiscoverable to any creditors searching for liens on Premium’s assets. We turn next to one such creditor.

1 All monetary sums are rounded to the nearest thousand. 4 No. 25-1419

2. MedLegal secures a federal judgment against Premium. MedLegal Solutions, Inc., a Delaware corporation with a principal place of business in California, provides medical billing management services to healthcare providers. Med- Legal paid Premium for the right to manage Premium’s out- standing accounts receivable—amounts owed by customers for products sold or services rendered on credit. As part of the deal, MedLegal agreed to negotiate and recover payments from patients or their personal injury attorneys pursuant to Premium’s health care liens. In return, Premium agreed that MedLegal could keep a portion of each payment before hand- ing over the remainder. But MedLegal discovered that Premium was collecting and retaining payments on accounts subject to their agree- ment without notice or payment. So, MedLegal filed an arbi- tration demand seeking damages for breach of contract. The arbitrator entered a money judgment for MedLegal and against Premium and awarded MedLegal attorney’s fees and costs. After this, but before filing a complaint, MedLegal’s search of Illinois state and federal court records did not reveal any judgments against Premium. With arbitration award in hand, MedLegal petitioned the Northern District of Illinois district court to confirm the award plus post–judgment interest. In July 2024, the district court, sitting in diversity, entered a judgment in favor of Med- Legal and against Premium for $488,000. Based on this July 2024 judgment, MedLegal issued a third-party citation to dis- cover Premium’s assets at BMO Bank and JP Morgan Chase Bank. Combined, the accounts held only a few thousand dol- lars, far less than what could satisfy MedLegal’s or Bedi’s judgments. No. 25-1419 5

3. Bedi and MedLegal initiate separate collection efforts. MedLegal’s discovery process apparently resulted in a freeze on the BMO Bank account, which held funds to which Bedi believed he was entitled. After nearly two years Bedi re- newed collection efforts in the Illinois state court. In August 2024, the DuPage County Clerk of Court issued a third-party citation to discover Premium’s assets held by Innovative Management Solutions, Inc., a billing management company which, like MedLegal, serviced Premium’s accounts receiva- ble from plaintiffs in worker’s compensation and personal in- jury cases. The state court issued a turnover order directing Innovative to pay all proceeds of these accounts, contract rights, and accounts receivable to Bedi “until the judgment entered in favor of Vivek Bedi is satisfied in full.” MedLegal’s collection efforts also continued apace. A month after the state court issued a turnover order on Bedi’s behalf, MedLegal moved to allow third-party citation pro- ceedings by deposition, which the district court granted. The district court also issued a citation to discover Premium’s as- sets, which MedLegal served on Premium in the days that fol- lowed. B. Bedi’s Petition to Intervene 1. Bedi intervenes in MedLegal’s federal collection efforts. Before Premium had responded, however, Bedi petitioned to intervene in MedLegal’s post-judgment collection proceed- ings in federal court. See FED. R. CIV. P. 24. In the meantime, that court issued nearly 70 citations on third parties, consist- ing mainly of law firms holding accounts receivable for 6 No. 25-1419

Premium. One citation was issued against Innovative, which was already subject to Bedi’s state court lien and turnover or- der. During a hearing on his petition to intervene, Bedi learned of the misnomer in his October 2022 judgment and subse- quent orders. So he returned to state court the next day to fix it.

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