The parties characterized the sole issue in the case as one of statutory construction. Federal Medicaid statutes provided for the assignment of rights to third-party payments, but prohibited the placing of a lien on a Medicaid recipient's property. Ahlborn argued that the settlement was her "property," and that this prohibition accordingly limited the State's recovery to only those portions of the payments made for medical expenses. The parties stipulated that the State would recover $215,645.30 if it prevailed on the statutory construction issue, representing the total amount the State paid in relation to Ahlborn's care, but only $35,581.47 if Ahlborn prevailed, representing 16.5 percent of the total, which was considered a fair representation of the percentage of the settlement constituting payment by the defendants for past medical care.