Adamson v. Bicknell, 287 P.3d 274

Bicknell rear-ended Adamson at a railroad crossing in July 2003; Adamson sought punitive damages based on impairment evidence and Bicknell’s admission of marijuana use.
Evidence included a post-collision drug screen positive for marijuana and cocaine, drug paraphernalia and substantial marijuana found in Bicknell’s vehicle, and testimony suggesting impairment and driver inattention.
District court denied Adamson’s punitive damages motion, citing lack of quantified impairment and inconclusive evidence of influence.
Court of Appeals reversed, holding district court abused discretion by requiring precise impairment quantification and by misapplying the standard for wanton conduct.
District court also ruled on medical bill write-offs under Bates v. Hogg, allowing certain Medicaid-related write-offs and excluding others; trial proceeded with a jury verdict.
The Court of Appeals decision was partially affirmed and partially reversed; case remanded for rehearing on punitive damages under the proper standard; medical write-off issue deemed not preserved for appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Correct standard for punitive damages amendment	Bicknell says district court overbore by demanding impairment science	Adamson says district court applied correct gatekeeping	Remanded for rehearing with proper standard on wantonness
Knowledge and imminence versus impairment level	Adamson argued impairment evidence supports wanton conduct	Bicknell argues lack of quantified impairment excuses punitive claim	Remanded to apply Reeves two-step wantonness test (imminence and indifference) rather than focus solely on impairment level
Preservation of medical bill write-off issue	Adamson argued Bates allows additional write-offs beyond Medicaid	Bicknell argued Bates controls admissibility and preservation	Issue deemed not preserved for appeal; Bates controls preserved aspect; final ruling affirmed

Reeves v. Carlson, 266 Kan. 310 (1998) (two-step wantonness test: knowledge of danger and indifference to consequences)
Fusaro v. First Family Mtg. Corp., 257 Kan. 794 (1995) (abuse of discretion standard in punitive damages review)
Bates v. Hogg, 22 Kan. App. 2d 702 (1996) (collateral source rule exception for Medicaid write-offs; preservation mechanics)
Smith v. Printup, 254 Kan. 315 (1993) (approval of submitting wantonness where facts show reckless disregard)
Frazier v. Cities Service Oil Co., 159 Kan. 655 (1945) (definition of wantonness involving knowledge of danger and indifference)