Garcia v. Centura Health Corp.

2025 CO 15. No. 24SA257. Hospital Lien Statute—Discovery Disputes—Abuse of Discretion.

April 14, 2025

After the supreme court remanded this case with instructions that the district court determine and make specific findings regarding whether certain discovery sought by Centura Health Corporation (Centura) was relevant to the claims and defenses in this case, keeping in mind that this lawsuit involves wrongful lien claims for which statutory damages are established by law, the district court again ordered that Garcia respond to substantial discovery requests propounded by Centura. Garcia petitioned for relief under C.A.R. 21, arguing that the district court violated the court’s prior mandate and abused its discretion in ordering the discovery at issue, and the court issued an order to show cause.

The court concluded that the district court abused its discretion in ordering the discovery at issue; therefore, Garcia is not required to respond to those discovery requests.

Accordingly, the court made its order to show cause absolute and remanded this case to the district court for further proceedings consistent with this opinion.