The Supreme Court Of Ohio Upholds The Holding Of Robinson v. Bates

In the 2006 decision of Robinson v. Bates, 112 Ohio St. 3d 17, 2006-Ohio-6362, 857 N.E.2d 1195, the Supreme Court of Ohio held that both the original medical bills as well as the amounts that were accepted as full payment by the medical providers were admissible in a personal injury action as evidence of the reasonable value of the medical services provided to a plaintiff. Robinson held that admission of the lesser or "written-off” amounts did not violate the collateral source rule because the write-offs did not constitute payment of a benefit. In Jaques v. Manton, S.C. No. 2009-0820, 2010-Ohio-1838, the Supreme Court of Ohio held that its holding in Robinson was not altered by the enactment of Ohio Revised Code Section 2315.20, which abrogated the collateral source rule, because the statute does not bar the introduction of write-offs.

For more information, contact Ray S. Pantle at 614-233-4756 or at rpantle@lanealton.com.