Tuscaloosa County v. Children's Hospital, Inc
In Tuscaloosa County v. Children's Hospital, Inc., 486 So. 2d 1302 (Ala. Civ. App. 1986), Children's Hospital sought repayment of medical care under the Act for an indigent patient residing in Tuscaloosa County.
Tuscaloosa County argued that the action was in tort and subject to a one-year statute of limitations. Children's Hospital argued that the action was in the nature of an open account. This court noted that the Act was intended to place the ultimate financial responsibility for medical treatment upon the county in which the indigent resides.
The court held that an action brought under the Health Care Responsibility Act is in the nature of an action on an implied contract, the terms of which are not fixed by the parties, making it an open account.