Patchett v. Lee

60 N.E.3d 1025 (2016)

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Nature Of The Case

This section contains the nature of the case and procedural background.

Facts

Patchett (D) admits she drove her car negligently in striking Lee's (P) vehicle and causing Lee injuries that required medical treatment. D admitted she was liable for the accident. D contests the reasonable value of D's medical care, so the parties prepared for a trial on damages. The parties disagree whether D could introduce evidence that P's providers accepted a reduced amount as payment in full. Specifically, because D was enrolled in the Healthy Indiana Plan (HIP), a government-sponsored health care program, her providers, as HIP participants, accepted HIP's prevailing reimbursement rates of $12,051.48 in full satisfaction of those charges-an 86-percent discount from the amounts billed. P moved before trial to prevent the jury from hearing the reduced HIP rates. The trial court granted P's motion. It found that the HIP payments are subject to the collateral-source statute and the court excluded the HIP amounts under Evidence Rule 403 because it found HIP's reduced rates would only confuse the jury.

Issues

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Holding & Decision

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Legal Analysis

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