California Appellate Court Holds Unpaid Medical Bills May Be Admitted Into Evidence Under Very Limited Circumstances

• Jurisdiction: California,United States
• Author: Mr Daniel Velladao
• Law Firm: Lewis Brisbois Bisgaard & Smith LLP
• Published date: 18 September 2021

San Diego, Calif. (September 16, 2021) - In Qaadir v. Figueroa (2021) 67 Cal.App.5th 790, the plaintiff sued the defendants for negligence arising from a car accident defendants caused. (Id. at p. 794.) The plaintiff sought treatment for his injuries from lien providers who did not accept his insurance plan. The plaintiff's medical bills remained unpaid at the time of the trial. (Ibid.) Prior to trial, the defendants admitted liability for the accident and the case proceeded to trial solely on damages. (Id. at p. 796.) The defendants moved in limine to exclude evidence of the plaintiff's unpaid medical bills. The trial court denied the defendants' motion. During trial, both parties had billing experts testify about the reasonableness of the medical bills. Neither of the billing experts relied upon plaintiff's unpaid medical bills to determine the reasonableness of the plaintiff's medical expenses. The jury eventually rendered a verdict against the defendants. The defendants timely appealed from the judgment. (Ibid.)

On appeal, the defendants argued that the trial court erred by admitting the plaintiff's unpaid...