Auto accident cases often involve serious injuries that require extensive (and expensive) medical care to treat. When the accident victim doesn’t have health insurance, this can become complicated. In an important new case on the issue of the issue of assessing economic damages (such as past medical expenses) in an auto accident case, the California Court of Appeal upheld a trial judge’s decision not to admit evidence about how much a third-party company paid medical providers for a lien those medical providers had on any civil judgment award the victim might receive from a lawsuit related to the wreck.
The case began when a vehicle driven by Clare Meline collided with a vehicle driven by Anna Uspenskaya at a busy intersection. The wreck caused Uspenskaya to suffer substantial back injuries. Uspenskaya ultimately required surgery to correct a herniated lumbar disc. Uspenskaya, at the time of the accident, did not have health insurance. In order to secure treatment, Uspenskaya entered into an agreement with her doctor and the hospital in which they agreed to treat her in exchange for a legal right to receive a cut from whatever damages award the patient might recover in a personal injury lawsuit. At some later point, the medical providers sold that lien at a discount to a third-party financial services entity, MedFinManagers LLC.
Uspenskaya sued Meline. At trial, Meline asked to introduce evidence regarding how much MedFinManagers paid to purchase the lien, arguing that this evidence went toward showing what the true, reasonable cost of the care Uspenskaya received was. The judge, however, rejected that request and kept the payment evidence out. In the end, the jury awarded Uspenskaya damages in excess of $429,000. That amount included $261,713 in past medical expenses, which was the full total of the medical bills that Uspenskaya submitted.
Meline appealed but was not successful. The appeals court agreed with the trial court that the evidence was relevant. The payments MedFinManagers made to the medical providers would have had some tendency to show what the reasonable value of the medical services Uspenskaya received was. The appeals court also agreed with the trial court that the value of that evidence in tending to prove the true worth of the services Uspenskaya received was relatively low.
On the flip side, admitting the evidence relating to the MedFinManagers payments would have a relatively strong likelihood of confusing or prejudicing the jury. That’s because the amount that MedFinManagers pays to medical providers is not based solely on the value of the medical services that the doctors or hospitals provide. The amount that MedFinManagers offered to Uspenskaya’s doctor and hospital was not a reflection solely of the value of the services they provided, but it was also a reflection of the collectability of the debt. This included several factors unrelated to the value of the providers’ services, such as MedFinManagers’ assessment of the relative strength of the victim’s legal case.
Meline cited several cases in which similar evidence was admitted. The cases were not persuasive, though, since they were factually different. The injury cases Meline cited involved medical providers who accepted a partial payment as a full settlement of the debt. In Uspenskaya’s case, the victim remained on the hook for the full amount of the lien.
Proving the total amount of damages in an auto accident case can be a complex venture. To get everything to which the law entitles you, you need to have skilled, experienced counsel on your side. The Oakland car accident attorneys at the Law Offices of Stephen M. Fuerch can help. Our attorneys are armed with the determination and the in-depth knowledge of the law and litigation procedure necessary to deliver the results you deserve. Contact us through our website or call our office at (925) 463-1073 to schedule your confidential initial consultation today.
More Blog Posts:
California Court Rules that Medical Bills, Expert Testimony Enough to Prove Damages in Multi-Million Dollar Auto Accident Case, Oakland Personal Injury Attorney Blog, July 15, 2015
Be Wary of the Release Agreements You Sign as Part of Your California Personal Injury Case, Oakland Personal Injury Attorney Blog, May 29, 2015