Wood v. Health Care Auth. for Baptist Health, No. SC-2025-0132, 2026 WL 1700849 (Ala. June 12, 2026). The Court (McCool, J.; Stewart, C.J., and Wise and Cook, JJ., concur; Bryan, J., concurs in the result; Shaw, J., dissents, with opinion, joined by Sellers and Parker, JJ.; Mendheim, J., dissents, with opinion) reverses the Montgomery Circuit Court’s dismissal of Wood’s interpleader and declaratory-judgment action, holding 5-4 that interpleader claims against state-owned hospitals to challenge the validity and amount of hospital liens do not implicate State immunity and thus do not deprive Alabama trial courts of jurisdiction.
Wood was a passenger in a vehicle driven by Tracy Horn and owned by Buna Palmer. *1. While traveling in Montgomery County, Horn drove on the wrong side of the road and collided with an oncoming vehicle. Id. Wood was seriously injured in the collision and received treatment from Baptist Medical Center South (“Baptist”) and USA Health University Hospital (“USA”). USA filed a hospital lien in the amount of $51,403.92, and Baptist filed a hospital lien in the amount of $125,726.30. Id. The liens, together totaling $177,130.22, exceeded the $75,000 in available insurance coverage from Palmer, the vehicle owner. Id.
Wood filed an interpleader and declaratory-judgment action in the Montgomery Circuit Court, asking the circuit court either to declare the liens invalid or to determine the fair and reasonable amounts owed. Id. USA moved to dismiss, arguing that, as a State agency, it was entitled to immunity under Article I, § 14, of the Alabama Constitution. Id. The circuit court agreed and concluded that it lacked subject-matter jurisdiction over USA. Id. at *2. The circuit court also found that USA was a necessary party and dismissed the claims against both hospitals with prejudice. Id.
On appeal, Wood argued that the circuit court erred because her interpleader claim did not implicate State immunity. Id. The Court agrees, relying on Ex parte Bd. of Trs. of Univ. of Alabama for Div., Univ. Hosp., No. SC-2025-0240, 2025 WL 3560223 (Ala. Dec. 12, 2025) and prior Alabama cases allowing interpleader actions to resolve hospital-lien disputes involving state-run hospitals. Id. at *2-3. The Court explains that interpleader is a proper procedural vehicle for litigating the validity and amount of hospital liens, even when the lien claimant is a state-owned university hospital. Id. The Court holds that the circuit court had jurisdiction over Wood’s interpleader claim, reverses the dismissal, and remands the case for further proceedings. Id. at *3-4.