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Arthur v. Catour In the World of Compensatory Damages A Consideration of Arthur v. Catour in the Context of Its Ancestors and its Progeny

IDC Quarterly Vol. 17, No. 3 (17.3.8)

Summary: This article deals with whether a plaintiff is entitled to submit the face amount of medical bills which have been satisfied at a “discount”. It recognizes the phenomenon that most healthcare providers bill the patient for amounts which greatly exceed those which the insurer pays and the healthcare provider accepts in full satisfaction. The battle lines were drawn over whether the so-called “discount” was a “collateral source” that the defendant was precluded from showing. The Arthur court held that a defendant should not be permitted to “benefit” from the “discount”. However, it affirmed the rule that a plaintiff must prove the “reasonable value” of the medical services which were received. That “value” could not be proved by simply admitting the bills into evidence as “paid”. Instead, and as is the case with unpaid medical bills, the plaintiff must prove the “reasonable cost” of the services that were rendered on the lips of the provider or by another source.  Read More