In California personal injury law, the rules for recovering medical damages are far more complex than simply presenting a medical bill to a jury. A trilogy of key appellate decisions has created a nuanced and sometimes challenging landscape for plaintiffs and their attorneys. Understanding the interplay between Howell v. Hamilton Meats, Corenbaum v. Lampkin, and Pebley v. Santa Clara Organics is essential for any attorney litigating an injury case.
These cases collectively address a central question: What is the “reasonable value” of medical care, and what evidence can be used to prove it?
Howell v. Hamilton Meats (2011): The Foundational Rule
The California Supreme Court in Howell established a foundational and often harsh rule for insured plaintiffs. The court held that an injured plaintiff can only recover the amount that was actually paid for their past medical care, not the initial, higher amount that was billed by the provider.
The court reasoned that because of negotiated discounts between insurance companies and medical providers, the “paid” amount is the true measure of the plaintiff’s economic loss. The discounted amount that is “written off” by the provider is considered a “phantom” damage that the plaintiff never actually incurred. The Howell ruling effectively capped the recovery of past medical specials at the amounts paid by the plaintiff’s insurer.
Corenbaum v. Lampkin (2013): Extending the Howell Logic
Two years later, the court in Corenbaum v. Lampkin addressed the next logical question: If the full, undiscounted bill can’t be recovered as a past medical expense, can it still be used for other purposes? The court’s answer was a firm no.
Corenbaum held that the full, undiscounted medical bills are not relevant and are inadmissible for proving non-economic damages (pain and suffering). The court worried that presenting these larger, “phantom” numbers to a jury would prejudice them and improperly inflate their valuation of the plaintiff’s suffering. Furthermore, Corenbaum clarified that the full bills are also not a reliable basis for projecting the cost of future medical care. Instead, experts must rely on the “paid” amounts to determine the reasonable value of future treatment.
Together, Howell and Corenbaum create a clear but often restrictive framework for plaintiffs who have health insurance.
Pebley v. Santa Clara Organics (2018): The Exception for the Uninsured and Lien Patients
The landscape shifted significantly with the Pebley decision, which carved out a critical exception. The court addressed the situation of a plaintiff who either has no health insurance or chooses to treat outside of their insurance network on a lien basis.
The Pebley court recognized that unlike an insured plaintiff, an uninsured or lien-based plaintiff is legally obligated to pay the full, undiscounted billed amount for their care. The provider is not contractually obligated to accept a lower, discounted rate. Therefore, the court held that for these plaintiffs, the full billed amount is relevant and admissible as evidence of the reasonable value of their medical services.
This creates two distinct paths for proving medical damages in California:
- For Insured Plaintiffs: The recoverable damages are capped at the amounts paid, and evidence of the full bills is generally inadmissible (Howell/Corenbaum).
- For Uninsured/Lien-Based Plaintiffs: The full, undiscounted bills are admissible as evidence of the reasonable value of the medical care, and they can potentially recover up to that amount (Pebley).
Navigating these distinct rules is critical in any personal injury case, from a car accident to a complex slip and fall claim. The plaintiff’s insurance status now fundamentally alters the evidence that can be presented and the potential value of the case.
Contact Manoukian Law for a free and confidential consultation to discuss how these landmark decisions impact the specifics of your case.
