Miller v. Beebe Medical Center

Summary

The Delaware Superior Court denied Beebe Medical Center’s motion in limine seeking to exclude evidence of the decedent’s medical bills under the collateral source rule. The court held that the record did not show Beebe or the other defendants paid the medical expenses or were sufficiently connected to the source of payment, making evidence of the reasonable value of the bills admissible.

Holdings

1. Evidence of the reasonable value of the decedent's medical bills was admissible because the record did not show that Beebe paid the expenses or that the Cardiology Defendants were connected to the plan or payment source.
2. Plaintiffs may introduce evidence of alleged loss-of-household-services damages.

Questions Presented

1. Whether the collateral source rule barred Plaintiffs from introducing evidence of the reasonable value of the decedent's medical bills because Beebe created or provided the health benefit plan.
2. Whether the evidence established that Beebe or the Cardiology Defendants were connected to the source of payment such that the defendants could benefit from payments made from that source.
3. Whether Plaintiffs could introduce evidence of alleged loss-of-household-services damages.

Disposition

other