According to Schwinghamer (2011), the California Supreme Court (CSC) ruled that plaintiffs who have injured themselves personally are not warranted full receipt of the entire amount if the insurers paid a small amount of the medical expenses. This decision was held on August 18, 2011. Rebecca Howell was the plaintiff, who was injured by a truck of Hamilton Meats. Her detriment led to injuries that required her to undergo two spinal injuries that totaled a medical bill of $190,000.Her insurer’s negotiation was capable of lowering the medical outlay to $ 60,000. Her attorney argued that the compensation of his client (Howell) should not be restricted to the payment of the $60,000 but rather $ 190,000 (Schwinghamer 2011). This will mean that Howell will get an additional $ 130,000 over her treatment expenses.
According to Schwartz & Guerrero (2011), the defendant of the case, Hamilton Meat Company, acknowledged liability of the offense and the hearing proceeded to the subject of damages. However, Hamilton and their insurers were insisting that the amounts paid are not obligatory and were subject to omission. Therefore, Hamilton requested the court to lower their payment consistent with the medical bill settlement (Chayet, Lefler & Newman 2011). Hamilton made a presentation of all the bills that were relevant to the case. It persuaded the court that their argument was eligible. On the contrary, the plaintiff was lamenting reduction of the compensatory damages would be an infringement of the “collateral source rule” (Schwartz & Guerrero 2011).
The Court Ruling
The trial court decided that Hamilton’s payment was to be consistent with the sum the hospital got on the treatment of the patient. It held justification of Hamilton was eligible to warrant the ruling presented by the court. The plaintiff to the Court of Appeal appealed this case and the reduction order was rejected. The appellate Court was insistent the trial court’s decision was contradicting the “collateral source rule” (Schwinghamer 2011). However, the appellate court did not adequately determine the compensation of Howell from Hamilton. It ruled that the compensation should be limited to the payment of the insurer for the medical bill.
Analysis of the Case (Justification of the Ruling)
The appellate court was affirming its ruling based on the following precedents One was compensatory damages, which illustrates a tort where an individual who attains injuries is experiencing economic loss is liable for the treatment expenses (Schwinghamer 2011). This insinuates the medical payments for the treatment are recoverable as damages. This was to affirm the claims of Howell to emphasize the economic loss experienced by her. The court would consider the injury that was imposed on Howell during her accident. However, the Supreme Court did not discern the impediment of Howell as an economic loss and was of the view that she did not have entitlement to the amounts that were previously charged. The excess amounts were not reflective of the true significance of the services (Schwinghamer 2011).
In dissident, one judge lamented that Hamilton eats would not be reimbursing the total cost of their negligence. According to Preston (2011), the large compensatory amount would help to ensure Hamilton did not engage in such heinous acts that purport to illustrate negligent behavior of drivers. The second foundation of their ruling was the “collateral source rule”. This rule asserts that the individual that sustains the injuries is eligible for payment of compensation from a representative of the perpetrator (Preston 2011).
The guarantor should be independent of the defendant who is answerable for the crime. It further claims that the compensatory fee cannot be deducted from the entitlement of damages of the perpetrator. This amplifies the decision that was held by the Supreme Court concerning the “collateral source rule” that, Howell, who was the victim of the Hamilton meat truck, is liable to the compensatory damages (Schwinghamer 2011). However, the court would determine that regardless of the precedent of the “collateral source rule” Howell would not enjoy the premiums of her medical bill since the insurer paid for the actual loss.
According to Preston (2011), the third basis of the Supreme Courts of the Hanif Case was a case, which the appellate court decided the plaintiff was over reimbursed for his injuries and his detriment, was not reflective of compensation surpassing a reasonable amount. This ruling was insinuating the plaintiff’s entitlement only extended to the value of medical expenses; therefore, he is not eligible to receive additional values if the actual loss was less (Chayet, Lefler & Newman 2011). In the eventuality the plaintiff negotiates for the lowering of the medical bill and pays less, the court determines that pecuniary loss is not existent and therefore he/she cannot recover the full amount of damages (Preston 2011).
Howell’s insurer negotiated the bill from $ 190,000 to $ 60, 000; hence, the claim of the Supreme Court that Hamilton was only liable to pay damages of $60, 000 and not the former substantial amount (Walter 2011). This precedent was applicable in hearings that the insurer of the plaintiff had received discounts on the medical bill. The ruling of the Haniff case emphasizes that although the plaintiff can argue that they are eligible for the payment, the liability of her insurer, is limited to the medical expense.
The exception to this precedent was if the damages consist of gratuitous payments. This will be in the form of donations and such was not applicable in Howell’s case since the payment negotiations were between the insurers and health providers (Walter 2011). The court supplemented their decision by affirming that the difference in price the insurers negotiate and the sum paid for by the perpetrator of the tort is not recoverable under law. The collateral rule majorly relates to the harm the plaintiff experiences and the additional values, which will be of benefit to the plaintiff (Preston 2011).
How does this law conform to the wider body of relevant laws?
The Hamilton Case was able to confirm the precedent of the Hanif Case. The Hamilton judgment took consideration of all the previous rulings of the “personal injury compensation” issue (Preston 2011). This ruling was favorable to the insurers since it will mitigate their obligatory payments in similar situations. This will appear inequitable to the injured person since payment will cover medical fees alone, it will not account for the physiological damage on the individual that is injured (Schwartz & Guerrero 2011). The plaintiff will have to be lenient on the demands for compensatory fees.
This law illustrates that an individual who suffers a loss due to injury by another person is eligible for compensation. However, the indemnity is limited to the price the insurer negotiates with the health provider (Schwartz & Guerrero 2011). The courts deem pecuniary loss of the injuries to the person to be relieved by the medical payment. The amount the health attendants acknowledge as payment is sufficient to recompense the detriment of the plaintiff (Chayet, Lefler & Newman 2011). This case was in support of precedents of the Hanif Case and the regulation on compensatory damages. The ruling emphasized that it is essential for plaintiffs not to search for commercial benefit in cases of personal injury.
References
Chayet, E., Lefler, R. & Newman, N. (2011). Howell v. Hamilton Meats & Provisions, Inc.Lexology. Web.
Preston, J.(2011). CA Supreme Court comes down in favor of big insurance, against consumers. Protect Consumer Justice.Org. Web.
Schwartz, A & Guerrero, C.(2011). Howell v. Hamilton Meats and Provisions. Inc. Gordon & Rees LLP. Web.
Schwinghamer, N. (2011). Howell v. Hamilton Meats and Provisions-Full Opinion. Sacramento Injury Lawyer. Web.
Walters, D. (2011). Insurers win, lawyers lose in big state Supreme Court ruling. Capitol Alert. Web.