Specifically, the complaint alleges that:

• the hospital is registered as a tax-exempt, non-profit organization and has a duty to provide charitable care, but requires all patients to sign a document agreeing to pay for services.
• the hospital engages in aggressive, abusive, and humiliating debt collection practices, including lawsuits, liens, garnishments, and harassing communications to recover for medical costs.
• AHA told its member hospitals that uninsured patients should be charged the same as those with insurance and conspired with the hospital to charge higher rates.

The Burgher family, Brett, his wife Deborah, and their minor son were patients at the hospital at various times. Brett Burgher was treated for a broken arm in 2003, Deborah Burgher was a patient from 1999 to 2002 for cancer treatments and their minor son was treated for a shoulder injury in 2002. The Burghers were uninsured during those visits, but were charged the full value for the care they received. They incurred additional interest and fee costs when they were not able to make the hospital payments. The Burghers claim that the hospital and/or its collection agents began to harass them for payment, including repeated telephone calls and correspondence, threats to seize property, repeated seizures of property and threats of lawsuits. As a result, the Burghers were forced in bankruptcy by the hospital’s bill, which at the time was over $100,000. They seek damages, injunctive relief, costs and attorney’s fees.