Brandon Stanley v. Danny Walker

Summary

The Indiana Supreme Court held that discounted amounts accepted by medical providers may be admitted, without referencing insurance, as evidence of the reasonable value of medical services in a personal injury action. The court concluded that Indiana's collateral source statute does not bar such evidence and remanded with instructions to reduce the damages award by $4,750, subject to the plaintiff's choice to accept the remittitur or retry damages.

Holdings

1. In a personal-injury action, discounted or accepted medical charges may be introduced as evidence relevant to the reasonable value of medical services, provided they are introduced without referencing insurance.
2. The trial court erred by instructing the jury that the original medical bills constituted prima facie evidence of reasonable and fair value without also allowing consideration of the discounted amount actually paid.
3. The judgment was affirmed subject to a $4,750 reduction in the damages award; if Walker rejected the remittitur, he could retry the damages issue before another jury.

Questions Presented

1. Whether evidence of discounted medical charges accepted by medical providers may be admitted, without referencing insurance, to rebut the prima facie reasonableness of the plaintiff's original medical bills.
2. Whether the trial court's jury instruction was erroneous because it identified the original medical bills as evidence of reasonable medical expenses but did not also identify the discounted amounts as admissible evidence.
3. What remedy was appropriate after the trial court improperly excluded the discounted medical-charge evidence.

Disposition

affirmed