In A Negligence Action, Should The Defendant Pay For The Plaintiff’s Medical Expenses?
Sometimes the black letter law passed by the legislature is unclear. The legislature can’t anticipate every possible fact scenario when they pass a law, so it lay to the courts to interpret the law and give guidance to what it means. This interpretation is called case law. When the court decides a certain meeting to the law it essentially answers a legal question. Lawyers and other courts then can rely on that ruling when they have a similar issue in their case. The following case answers the question above.
Hyman v. Robinson, 713 S.W.2d 300 (Mo. Ct. App. 1986).
This case addresses the following issue:
In a negligence action, should the defendant pay for the plaintiff’s medical expenses?
This case explored the issue of whether the defendant should pay for the plaintiff’s medical expenses in a negligence action. In exploring this issue, the court concluded that the fundamental principle of the law of damages was that a person who suffered personal injuries because of the negligence of another was entitled to recover the reasonable value of medical care and expenses for treatment of his or her injuries, as well as the cost of those reasonably certain to be encountered in the future. Id. at 252.
The plaintiff and defendant were involved in an automobile accident in January 1992. Id. at 251. The defendant’s pickup truck, traveling at approximately 40 miles per hour, struck the plaintiff’s vehicle from behind. Id. Prior to trial, the defendant asked to court to limit the plaintiff’s evidence of economic (monetary) damages to the amounts actually paid by Medicaid on the plaintiff’s behalf. Id. The defendant wanted to prevent the plaintiff from introducing evidence concerning the market value or list price of the services the plaintiff received. Id. In response, the trial court limited the plaintiff’s evidence of economic damages. Id. After trial, the jury returned a verdict, finding the defendant 100% at fault and awarding the plaintiff $1,305.23 in medical expenses. Id. at 252. As a result of the verdict, the plaintiff appealed the awarded damages. Id.
The plaintiff argued that the trial court should not have prohibited her from presenting evidence of the full value, or market value, of the medical treatment she received as a result of the accident. Id. Further, the plaintiff felt like it was wrong that the trial court limited her to only presenting evidence of what Medicaid actually paid on her behalf. Id.
The court noted that the ultimate question was whether an injured plaintiff could include, in a claim for economic damages, amounts that had been written off by the health care provider in combination with a Medicaid contract. Id. According to the court, both sides agreed that whether such evidence was admissible was a question of law for the court. Id. With this in mind, the court determined that the purpose of awarding damages was to make a party whole by restoring that party to the position he or she was in prior to the injury. Id. Moreover, the court stated that the fundamental principle of the law of damages was that a person who suffered personal injuries because of the negligence of another was entitled to recover the reasonable value of medical care and expenses for treatment of his or her injuries, as well as the cost of those reasonably certain to be encountered in the future. Id.
Ultimately, the court concluded that the trial court was justified in limiting the plaintiff to only presenting evidence of what Medicaid actually paid on her behalf. Id. at 253. The court indicated that a medical provider could not charge Medicaid patients for the difference between their full value charge and the amount paid by Medicaid. Id. Therefore, the court specified that the amount allowed by Medicaid became the amount due and was the “full value charge” under the circumstances. Id. Furthermore, the court referenced a federal case that stated, “It would be unacceptable to permit the taxpayers to bear the expense of providing free medical care to a person and then allow that person to recover damages for medical services from a wrongdoer and pocket the windfall.” Id. Basically, if the real reason for damages was to make the party whole, it would not make sense for the plaintiff to have his or her medical expenses paid for by Medicaid and then receive additional money. Id.