Weston v. AKHappytime, LLC, 445 P.3d 1015

Plaintiff Lorena Weston slipped on ice in a hotel parking lot, suffered fractures, and underwent complex surgery; the hospital billed about $135,000.
Medicare paid $24,247.45 (about 18% of billed charges) and the providers accepted that payment.
Weston sued the hotel (AKHappytime) for negligence and sought to admit the full undiscounted medical bills as evidence of past medical damages and injury severity.
The superior court excluded the undiscounted bills, allowing only the adjusted/preferred rates actually accepted as payment.
The Alaska Supreme Court granted review and reversed: it held undiscounted bills are admissible as evidence of reasonable value, and the negotiated write-off is a collateral-source benefit subject to post-verdict reduction under AS 09.17.070.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether undiscounted medical bills are admissible as evidence of past medical damages and injury severity	Weston: full billed amounts are relevant proof of the reasonable value and severity of care and should be admitted	AKHappytime: billed amounts are "inflated"; only amounts actually paid (Medicare rates) are admissible and recoverable	Court: Undiscounted medical bills are admissible as evidence of reasonable value and severity; jury may consider them
Whether the difference between billed amounts and amounts paid (the negotiated rate differential) is a collateral-source benefit and how it is treated	Weston: the write-off is part of the collateral benefit and cannot reduce damages at trial; reduction (if any) must occur post-verdict under AS 09.17.070	AKHappytime: the write-off is not the plaintiff's benefit and amounts actually paid show reasonable value	Court: The negotiated differential is a collateral-source benefit; evidence of amounts paid is excluded from jury consideration but may be used post-verdict under AS 09.17.070 to seek reduction of the award

Loncar v. Gray, 28 P.3d 928 (Alaska 2001) (collateral-source evidence of Medicaid was properly excluded at trial; post-verdict procedures apply)
Luther v. Lander, 373 P.3d 495 (Alaska 2016) (amounts insurer paid are relevant to injury severity and should not be categorically excluded)
Lucier v. Steiner Corp., 93 P.3d 1052 (Alaska 2004) (dissent argued undiscounted bills are collateral-source benefits and should be excluded from jury)
Dedmon v. Steelman, 535 S.W.3d 431 (Tenn. 2017) (adopted reasonable-value approach; undiscounted bills admissible and discounted amounts barred from trial rebuttal)
Howell v. Hamilton Meats & Provisions, Inc., 52 Cal.4th 541 (Cal. 2011) (adopted actual-amount-paid approach limiting recovery to amounts paid, criticized by majority in this opinion)