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Haygood v. De Escabedo, 356 S.W.3d 390, 54 Tex. Sup. Ct. J. 1377

Facts

Aaron Glenn Haygood was injured in an automobile accident when his car collided with Margarita Garza De Escabedo's minivan. Haygood underwent surgeries for his neck and shoulder injuries, which were successful but left him with some impairment. His health care providers billed a total of $110,069.12, but due to Medicare adjustments, the amount owed was reduced to $27,739.43, of which $13,257.41 had been paid and $14,482.02 was still due. The trial court allowed the jury to consider the full billed amount, leading to a verdict that included past medical expenses exceeding what was actually paid.

Aaron Glenn Haygood was injured in an automobile accident when his car collided with Margarita Garza De Escabedo's minivan. Haygood underwent surgeries for his neck and shoulder injuries, which were successful but left him with some impairment. His health care providers billed a total of $110,069.12, but due to Medicare adjustments, the amount owed was reduced to $27,739.43, of which $13,257.41 had been paid and $14,482.02 was still due. The trial court allowed the jury to consider the full billed amount, leading to a verdict that included past medical expenses exceeding what was actually paid.

Issue

Whether the Texas Civil Practice and Remedies Code section 41.0105 limits recovery of medical expenses to the amount actually paid or incurred by the claimant.

Whether the Texas Civil Practice and Remedies Code section 41.0105 limits recovery of medical expenses to the amount actually paid or incurred by the claimant.

Rule

Section 41.0105 of the Texas Civil Practice and Remedies Code limits recovery of medical or health care expenses incurred to the amount actually paid or incurred by or on behalf of the claimant.

Section 41.0105 of the Texas Civil Practice and Remedies Code limits recovery of medical or health care expenses incurred to the amount actually paid or incurred by or on behalf of the claimant.

Analysis

The Texas Supreme Court analyzed the statutory language of section 41.0105, concluding that it clearly limits recovery to amounts that have been or will be paid. The court emphasized that the adjustments made by health care providers due to Medicare regulations meant that Haygood could not recover the full billed amount, as the providers had no legal right to collect those excess charges. The court also addressed the collateral source rule, stating that it does not allow recovery for amounts that a provider is not entitled to charge.

The Texas Supreme Court analyzed the statutory language of section 41.0105, concluding that it clearly limits recovery to amounts that have been or will be paid. The court emphasized that the adjustments made by health care providers due to Medicare regulations meant that Haygood could not recover the full billed amount, as the providers had no legal right to collect those excess charges. The court also addressed the collateral source rule, stating that it does not allow recovery for amounts that a provider is not entitled to charge.

Conclusion

The Texas Supreme Court affirmed the Court of Appeals' judgment, holding that Haygood could not recover medical expenses that exceeded what was actually paid or owed, thereby disapproving conflicting decisions from other courts.

The Texas Supreme Court affirmed the Court of Appeals' judgment, holding that Haygood could not recover medical expenses that exceeded what was actually paid or owed, thereby disapproving conflicting decisions from other courts.

Who won?

Margarita Garza De Escabedo prevailed in the case because the Texas Supreme Court upheld the limitation on recovery of medical expenses to amounts actually paid or incurred.

Margarita Garza De Escabedo prevailed in the case because the Texas Supreme Court upheld the limitation on recovery of medical expenses to amounts actually paid or incurred.

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