Mary K. Patchett v. Ashley N. Lee
46 N.E.3d 476
Ind. Ct. App.2015Background
- On July 5, 2012 Ashley Lee was injured in a car accident caused by Mary Patchett; medical providers billed $87,706.36. Lee was enrolled in the state-sponsored Healthy Indiana Plan (HIP), which paid providers $12,051.48 in full satisfaction of her bills. Patchett admitted negligence; the case proceeded to trial on damages.
- Lee moved in limine to exclude evidence of the HIP reimbursements as barred by Indiana’s collateral source statute. The trial court granted the motion and certified the order for interlocutory appeal.
- The narrow legal question was whether evidence of government-set reimbursement amounts (HIP/Medicaid-like rates) is admissible to help the jury determine the “reasonable value” of medical services under Stanley v. Walker and the collateral source statute.
- Patchett argued Stanley’s rule allowing admission of negotiated discounts should extend to any reduced payment accepted in full satisfaction (regardless of source). Lee and amicus ITLA argued HIP payments are government-fixed, non‑negotiated rates and therefore not probative of reasonable value.
- The trial court excluded the HIP payment amounts under the collateral source statute and, alternatively, under Evidence Rule 403 as confusing/misleading. The appellate court affirmed.
Issues
| Issue | Plaintiff's Argument (Lee) | Defendant's Argument (Patchett) | Held |
|---|---|---|---|
| Whether evidence of HIP (government) reimbursement amounts is admissible to show the reasonable value of medical services | HIP payments are government-set, non‑negotiated, and therefore not probative of reasonable value; collateral source statute bars admission | Stanley allows admission of discounted/accepted-payment amounts (not just billed amounts) to assist the jury in determining reasonable value, regardless of payer | Court held HIP payments are inadmissible: Stanley applies only to negotiated discounts; government‑set rates are not probative of reasonable value and may be excluded under the collateral source statute and/or Rule 403 |
Key Cases Cited
- Stanley v. Walker, 906 N.E.2d 852 (Ind. 2009) (adopted a hybrid rule allowing jury to consider billed amount, amount accepted, or something in between when discounted amounts result from negotiation)
- Shirley v. Russell, 663 N.E.2d 532 (Ind. 1996) (discussed collateral source rule/statute and legislative abrogation of common‑law rule)
- Butler v. Indiana Department of Insurance, 904 N.E.2d 198 (Ind. 2009) (interpreted recoverable medical expenses under a statutory wrongful‑death framework to be amounts accepted after contractual adjustments)
- Robinson v. Bates, 857 N.E.2d 1195 (Ohio 2006) (adopted the hybrid approach permitting admission of billed and accepted amounts to aid jury in valuing medical services)