DTCI: Patchett v. Lee: The end of the fight over the admissibility of medical write-offs?

November 16, 2016 By Blake N. Shelby
The Indiana Lawyer

Personal injury cases present unique evidentiary challenges relating to the reasonable value of medical expenses incurred by the plaintiff. Indiana Evidence Rule 413 provides one method of proving the reasonable value of medical expenses. Stanley v. Walker, 906 N.E.2d 852, 856 (Ind. 2009). It reads: “[s]tatements of charges for medical, hospital or other health care expenses for diagnosis or treatment occasioned by an injury are admissible into evidence.” Id. (citing Evid. R. 413). “Such statements shall constitute prima facie evidence that the charges are reasonable.” Id. By its terms, Rule 413 allows actual past medical charges to serve as prima facie evidence that the charges are reasonable.

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