Prior Case Law Interpreting “Reasonableness” of Medical Expenses Under Tennessee Hospital Lien Act Did Not Apply in Car Accident Personal Injury Case – Dedmon v. Steelman

In negligence lawsuits, including those arising from car accidents, the burden is on the plaintiff to prove duty, breach of duty, causation, and damages. If the plaintiff is seeking to recover medical expenses as part of his or her damages, this burden usually requires expert medical testimony concerning the reasonableness and necessity of such expenses.

A recent appellate court case shows just how hard defendants – or, in reality, their insurance carriers – will fight against paying an injured party’s medical expenses in some cases.

Facts of the Case

In the recent case of Dedmon v. Steelman, the Court of Appeals of Tennessee was presented with an interlocutory appeal concerning the reasonableness of an injured woman’s medical expenses in a motor vehicle collision case. The plaintiffs were a husband and wife who filed suit against an allegedly negligent motorist, seeking compensation for injuries that arose in a car accident. The plaintiffs attached copies of over $50,000 in medical expenses to their complaint.

During the course of the litigation, the plaintiffs deposed one of the wife’s treating physicians, who testified that he had reviewed the wife’s medical expenses and opined that they were appropriate, reasonable, and necessary. The plaintiffs filed the deposition with the court and attached the medical bills as exhibits.

The defendant filed a motion in limine seeking to exclude evidence of what they deemed to be “unreasonable medical charges” in light of the Tennessee Supreme Court’s 2014 decision in West v. Shelby County Healthcare Corp. According to the defendant, the plaintiffs could only claim the “discounted amount” of medical expenses that their health insurer paid, not the full amount billed by the providers. The plaintiffs opposed the motion, pointing out that West involved the Tennessee Hospital Lien Act and that the current case did not involve a hospital lien. The trial court granted the defendant’s motion, and the plaintiffs sought interlocutory relief.

The Ruling of the Court of Appeals of Tennessee

On appeal, the court reversed the trial court’s order granting the defendant’s motion. First, the court noted that the Tennessee trial courts that had been called upon to determine whether West applied in personal injury suits were divided on the issue. The court went on to hold that the plaintiffs’ view was correct, thus rejecting the defendant’s assertion that West controls the determination of the reasonableness of medical expenses in personal injury litigation.

To Talk to an Experienced Tennessee Car Accident Attorney

If you have been hurt in a wreck, you need a strong representative who will fight hard against the negligent party’s insurance company for maximum compensation for your injuries. To talk to an experienced, hard-working Tennessee car accident attorney about your case, call the Hartsoe Law Firm, P.C., at (865) 804-1011 for a free consultation. If necessary, we will be glad to come to your home to discuss your case. Our offices are located in Knoxville, and we represent injured people throughout Tennessee, including in Oak Ridge, Maryville, Lenoir City, Rockwood, Crossville, Telico Plains, and Pigeon Forge.

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