Mary K. Patchett v. Ashley N. Lee, 60 N.E.3d 1025

Ashley Lee was injured in a 2012 car accident; defendant Mary Patchett conceded liability but disputed the reasonable value of Lee’s medical care.
Lee’s providers billed $87,706.36; as a Healthy Indiana Plan (HIP) participant they accepted $12,051.48 as full payment (an ~86% reduction).
Lee sought to exclude evidence of the reduced HIP reimbursements at trial; the trial court excluded them under Indiana’s collateral-source statute and Evid. R. 403.
The Indiana Court of Appeals affirmed the exclusion, interpreting Stanley v. Walker as limited to privately negotiated discounts.
The Indiana Supreme Court granted transfer, vacated the Court of Appeals opinion, and reversed, holding accepted reimbursements (including government payer rates) are admissible if introduced without referencing the payer.

Issue	Plaintiff's Argument (Lee)	Defendant's Argument (Patchett)	Held
Whether reduced reimbursements accepted by providers from a government payer (HIP) are admissible to prove the reasonable value of medical services	HIP discounts are collateral-source payments excluded by statute; admission would reference a government payer and is barred	Stanley allows admission of discounted/accepted amounts to prove reasonable value so long as the source (insurance/government) is not referenced	Admissible: Stanley’s rationale extends to government-payor rates; admissible if source not referenced
Whether exclusion of the HIP amounts was proper under Evid. R. 403	Admission would confuse or mislead the jury about how to use the amounts	Probative value of accepted amounts outweighs any risk of confusion; juries can weigh billed vs accepted amounts	Exclusion was an abuse of discretion; Rule 403 usually will not justify barring accepted-reimbursement evidence when billed amounts are admitted

Stanley v. Walker, 906 N.E.2d 852 (Ind. 2009) (held collateral-source statute does not bar evidence of discounted amounts if the source is not referenced)
Cook v. Whitsell-Sherman, 796 N.E.2d 271 (Ind. 2003) (standard for de novo review when legal interpretation controls evidentiary ruling)
Nichols v. Minnick, 885 N.E.2d 1 (Ind. 2008) (compensatory damages aim to make plaintiff whole; measure is reasonable value)
City of Indianapolis v. Gaston, 58 Ind. 224 (Ind. 1877) (fair value — not out-of-pocket expense — is the proper measure for physician services)
Howell v. Hamilton Meats & Provisions, Inc., 257 P.3d 1130 (Cal. 2011) (both billed charges and accepted amounts may be considered when determining reasonable value)