Phoebe Sumter Medical Center sued GEICO to enforce a hospital lien for treatment provided after a motor-vehicle collision. The trial court granted GEICO summary judgment, reasoning that the Medical Center had not perfected the lien because it did not attempt to serve a notice of intent on GEICO or its insured. The Court of Appeals of Georgia reversed. It held that the hospital-lien statute did not impose the service requirement used by the trial court and that the remaining diligence question had not been decided below. The case was remanded for the trial court to determine the level of diligence required under the statute.