Moore v. Mercer

Evidence of the amount a medical finance company paid the provider for its lien on plaintiff’s personal injury claim is properly excluded as it is only marginally relevant to the reasonable value of the medical provider’s services, and rebuttal evidence would consume too much time, distracting the jury from the central issues in the case.  Plaintiff, who lacked medical insurance, signed medical lien agreements with the doctors who treated her for the injuries she suffered due to defendant’s crashing into her car.  The medical providers, in turn, sold their lien claims to MedFinManager, a medical finance company.  Held, the amounts MedFin paid for the medical liens did not set the upper limit on the reasonable market value of the medical services provided to plaintiff.  Although the amounts paid fell within the broad scope of relevance that governs discovery—and so the trial court erred in sanctioning defendant for moving to compel production of those amounts—the trial court could, in the exercise of its discretion under Evid Code 352, exclude from trial all evidence regarding what MedFin paid for the medical liens.  The amount MedFin paid was only marginally relevant, and admitting that evidence would lead to medical providers putting in evidence of a lot of otherwise irrelevant evidence about why they were willing to accept less than full market value for their services.

California Court of Appeal, Third District (Raye, P.J.); October 21, 2016; 2016 WL 6135335


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