The court found an anti-assignment provision enforceable, thereby denying coverage for the assignee. Dameron Hospital Assoc. v. State Farm Mutual Automobile Ins. Co., 2012 U.S. Dist. LEXIS 146577 (E.D. Cal. Oct 20, 2012).

   Dameron Hospital provided emergency medial treatment to three individuals who were in automobile accidents and had coverage through State Farm. Each individual assigned benefits from his or her policy by signing a conditions of admission form which assigned policy rights to Dameron up the the amount of charges by the hospital.

   State Farm denied coverage because its policy stated, "No change of interest in this policy is effective unless we consent in writing." State Farm never gave written consent to the three insureds' purported assignments.

   The court noted that under California law, contracts may expressly provide that they are not to be assigned and such provisions were enforcable. Dameron argued there was a strong public policy in favor of free transferability of all types of property and the prohibition did not apply where all that remained to be done under the contract was the payment of money.

   The court held the anti-assignment provision was enforceable here and granted summary judgment to State Farm. State Farm had never consented to the assignment. Further, at the time of the assignments, Dameron's claim for benefits had not been reduced to a sum of money due or become due under the policy.