## Facts

- While jailed in Saraland, Alabama, K.A.L. attempted suicide by hanging and was found pulseless; CPR was initiated and paramedics detected a weak pulse and minimal breathing.
- K.A.L. was transported to Springhill Memorial Hospital, arrived comatose with fixed, dilated pupils, was intubated, and admitted to the ICU.
- She improved with treatment and was discharged nine days later, with residual speech difficulty and upper-extremity tremors.
- The hospital charges for the December 1998 admission were not paid.
- Southern Medical Business Services, as assignee of the hospital’s claim, sued K.A.L. and the City of Saraland to recover the unpaid charges.
- The City obtained a final summary judgment and was no longer part of the case; the trial court later entered summary judgment for Southern Medical against K.A.L. for $21,562.
- On appeal, K.A.L. did not contest the amount billed or the reasonableness and necessity of the services; she argued only that she was not liable because she was unconscious and did not consent to treatment.

## Issues

1. Whether an unconscious patient who did not expressly consent to emergency medical treatment may be held liable, under implied-contract or quasi-contract principles, for the reasonable value of necessary medical services.

## Decision

- The Alabama Court of Civil Appeals affirmed summary judgment for Southern Medical.
- The court held that, on undisputed facts, K.A.L. was liable for the reasonable value of necessary medical services even without express consent.
- Because K.A.L. presented no substantial evidence creating a genuine dispute as to liability, Southern Medical was entitled to judgment as a matter of law.

## Legal Principles

- A contract may be implied, or an obligation imposed in quasi-contract, to require payment for necessary medical services where equity demands compensation and the services were not intended to be gratuitous.
- Emergency, life-saving medical treatment provided to a person incapable of consenting can support recovery in quantum meruit for the reasonable value of the services.
- Under Alabama summary-judgment practice, once the movant makes a prima facie showing of entitlement to judgment, the nonmovant must produce substantial evidence of a genuine issue of material fact; purely legal opposition fails where the relevant facts are undisputed.

## Conclusion

The court held that an unconscious inmate who received undisputedly necessary and reasonably valued emergency hospital care could be required to pay for that care under implied-contract or quasi-contract principles, despite the absence of express consent, and it therefore affirmed summary judgment for the hospital’s assignee.


K.A.L. v. S. Med. Bus. Servs., 854 So. 2d 106 (Ala. Civ. App. 2003)