The Collateral Source Rule and the Hanif Nishima Debate Continue

Let's say that you are involved in a personal injurypaid by the injury victim's health insurance company for
accident in San Francisco. Let's also assume that likeher medical care.
thousands of other folks in the San Francisco BayIn other words, what does the difference between
Area you have private health insurance (mostly likelywhat was charged and what was paid represent?
through your workplace or employer).The Court answered - a benefit within the meaning of
So, you go to the hospital for your injuries, say Santhe collateral source rule.
Francisco General - and the good folks there send outTo put this as simply as possible: in California, the
bills for one amount (what was charged) but acceptcollateral source rules states that collateral source
as payment from your insurance company anotherpayments such as insurance or disability are irrelevant
amount (what was paid).in a personal injury trial. The bad guys don't get the
If you go to trial on your personal injury case, whichbenefit of the injury victim being responsible and having
amount do you get at trial (assuming you win ofinsurance. So, a jury is not allowed to hear about
course) - what was charged or what was paid?collateral source benefits like health insurance and an
Well, the Fourth Appellate District of California Howell v.award by a jury to an injury victim is not reduced
Hamilton Meats answered that question: the jury isbecause of such payments for her medical treatment.
able to award the injury victim what was charged.When a hospital negotiates with a health insurance
And assuming they do, you, the injury victim, arecompany and agrees to take less that what it would
entitled to obtain without reduction what was chargednormally charge for its services, it is not out of the
by your hospital.goodness of its heart. It is because it is getting
The scenario that I outline above is one that hassomething for that reduction - a certain volume of
caused an endless debate between personal injurybusiness, faster payments, advertising, all sorts of
attorneys (not just in San Francisco but acrossthings. Those things - those in-kind benefits - are
California) and insurance defense counsel.benefits within the meaning of the collateral source
Personal injury attorneys, like myself, want the jury torule.  And when a hospital agrees to accept as full
hear, be able to award, and the injury victim to bepayment the negotiated rate - meaning the injury
entitled to, what was charged.  And insurancevictim doesn't owe any additional amount - that too is
defense attorneys want the injury victim to be entitleda benefit within the meaning of the collateral source
to what was paid.rule.
The Court in Howell added their two cents bySo, the Court ruled that you can't reduce the plaintiff or
examining the collateral source rule, its application, andinjury victim's award by the difference between what
fully evaluating what resides in the gap between whatwas charged and what was paid because that
is charged by a hospital to an injury victim and what isdifference is a collateral source benefit.  So there!