Wal-Mart Stores, Inc., Petitioner v. Larry Crossgrove, Respondent

Summary

The court held that Colorado's common-law pre-verdict collateral-source rule requires exclusion of evidence showing the amount an insurer paid toward a plaintiff's medical bills, even when offered to establish the reasonable value of medical services. The applicable statute abrogates only the post-verdict component of the common-law rule and does not clearly eliminate the pre-verdict evidentiary bar. The court therefore affirmed the court of appeals' decision vacating the damages judgment and remanding for a new trial on damages. Justice Eid, joined by Justices Coats and Boatright, dissented, concluding that the amount accepted for medical services was relevant to reasonable value and that the identity of the payer was immaterial.