Kendig v. Consolidated Rail Corporation

Summary

The United States District Court for the District of Maryland considered whether medical expenses paid under Travelers Group Policy No. GA-23000 were subject to the collateral source rule in a Federal Employers’ Liability Act action. The court held that the on-duty injury benefits were indemnification rather than employee fringe benefits, making a set-off for medical expenses already paid appropriate. The court nevertheless permitted the plaintiff to introduce evidence of the medical expenses to establish the nature and extent of his injuries, subject to rebuttal concerning amounts already paid.

Holdings

1. The on-duty injury benefits under Policy GA-23000 were indemnification rather than employee compensation or a fringe benefit, so the collateral source rule did not preclude a setoff of medical expenses paid on the railroad’s behalf.
2. Although the railroad was entitled to a setoff for medical expenses paid under Policy GA-23000, plaintiff could still introduce evidence of those bills and expenses because the evidence was relevant to the extent and nature of his injuries.

Questions Presented

1. Whether medical payments made under Travelers Group Policy No. GA-23000 were collateral-source benefits that could not reduce plaintiff’s tort recovery.
2. Whether plaintiff could introduce evidence of medical expenses that had already been paid on the railroad’s behalf.

Disposition

other