Summary
The Rhode Island Supreme Court held that Medicaid is not a "state income disability" act within the meaning of Rhode Island General Laws § 9-19-34.1. Accordingly, Medicaid payments could not be introduced as collateral-source evidence to reduce damages in the medical malpractice action. The court affirmed the Superior Court's judgment and declined to reach the plaintiff's federal preemption and constitutional arguments.
Holdings
- Medicaid is not a state income disability act within the meaning of § 9-19-34.1, and Medicaid payments therefore are not admissible collateral-source payments for reducing a plaintiff's medical-malpractice damages under that statute.
- A statute that narrows the common-law collateral-source rule and limits a plaintiff's recovery is not to be liberally expanded merely because it is intended to address broader social or insurance-cost concerns.
Questions Presented
- Whether Medicaid benefits qualify as payments made pursuant to a state income disability act under Rhode Island General Laws § 9-19-34.1 and therefore may be introduced to reduce damages in a medical-malpractice action.
- Whether the court needed to reach plaintiff's federal-preemption, due-process, and equal-protection challenges to § 9-19-34.1.
Disposition
affirmed
Cases Cited (18)
- Webster v. Perrotta, 774 A.2d 68 (R.I. 2001)(followed)
- Carlson v. McLyman, 77 R.I. 177, 74 A.2d 853 (1950)(followed)
- Simeone v. Charron, 762 A.2d 442 (R.I. 2000)(followed)
- Moniz v. Providence Chain Co., 618 A.2d 1270 (R.I. 1993)(followed)
- Votolato v. Merandi, 747 A.2d 455 (R.I. 2000)(followed)
- Colvin v. Goldenberg, 108 R.I. 198, 273 A.2d 663 (1971)(followed)
- Oddo v. Cardi, 100 R.I. 578, 218 A.2d 373 (1966)(followed)
- Boucher v. Sayeed, 459 A.2d 87 (R.I. 1983)(followed)
- St. Paul Fire & Marine Insurance Co. v. Barry, 438 U.S. 531, 537 n. 6, 98 S. Ct. 2923, 57 L. Ed. 2d 932 (1978)(followed)
- Brown v. Stewart, 129 Cal. App. 3d 331, 341-42, 181 Cal. Rptr. 112 (1982)(considered)
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Cited In (0)
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Court Document
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