In a great victory for people injured in Tennessee, Nahon, Saharovich & Trotz lawyers Glenn Vines, Mark Geller, Kevin Graham, and Jason Yasinsky were able to ensure injured victims have the right to submit the full value of their medical expenses in their personal injury claim. This case, Dedmon v. Steelmon, was argued all the way up to the Tennessee Supreme Court.
Plaintiff Jean Dedmon originally filed suit in the Circuit Court of Crockett County, Tennessee, for injuries sustained in an automobile accident. As part of the lawsuit, Dedmon attached her full medical bills for hospital treatment and doctor visits caused by the accident. While the case was pending, the Supreme Court of Tennessee issued an opinion in another case, West v. Shelby County Healthcare Corporation. That case dealt primarily with hospitals that filed liens (pursuant to Tennessee’s Hospital Lien Act) for the full amount of treatment billed to the patient, regardless of whether they had health insurance. While health insurance companies often pay at discounted rates due to contractual agreements with providers, the Court ultimately decided that based on the language of the hospital lien law, the hospital’s lien is limited to the discounted amount paid by the patient’s health insurance company.
Counsel for Steelman took that holding and sought to apply the principle to all of Dedmon’s medical bills. The trial court agreed and ruled that Dedmon could not submit the full amount of her medical expenses to the jury; instead, she could only submit the amounts of the contractually-agreed payments that the providers accepted from her insurance company. NST Law, on behalf of Dedmon, appealed that decision. After both sides submitted legal briefs and argued their respective positions, the Tennessee Court of Appeals reversed the trial court ruling, stating Dedmon could introduce her full bills but Steelman could introduce proof contradicting the reasonableness of those bills. Steelman moved to appeal this ruling to the Tennessee Supreme Court.
Once the Tennessee Supreme Court accepted the appeal, lawyers on both sides continued to fight for their respective positions. Counsel for Steelman argued the Court should adopt a new standard and effectively overrule Tennessee’s collateral source doctrine by stating medical expense damages at trial should be limited to amounts paid by insurance companies. The team of NST lawyers, on behalf of Dedmon, argued the opposite, that people who cause harm to others should not benefit from the injured victim’s insurance payments. Our attorneys pointed out how healthcare has become increasingly complex, and patients would be treated differently based on their insurance status. For instance, private health insurance companies typically pay higher rates than government funded plans like Medicare and Medicaid. Further, patients with and without health insurance would be treated differently under the approach advocated by Steelman.
Ultimately, the Tennessee Supreme Court unanimously sided with Dedmon. The Court ruled the collateral source rule still remains valid law in Tennessee. Thus, plaintiffs can submit full, undiscounted medical bills as proof of medical expenses incurred following an accident. The Court pointed out “medical expenses cannot be valued in the same way one would value a house or a car,” as “health care services are highly regulated and rates are skewed by countless factors, only one of which is insurance.”
We are proud of our lawyers who fought not only for our client, but also on behalf of all injured victims across the State of Tennessee. This helps ensure all injured victims can pursue justice and fight to be fully compensated after being harmed through no fault of their own.
The full opinion can be found here: Dedmon v. Steelman. Nahon, Saharovich & Trotz represents victims of car and truck accident cases throughout Tennessee, Arkansas, Mississippi, Missouri, and Kentucky. For a free and confidential consultation with a lawyer, call us at 800-529-4004 or complete our contact form.