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

Summary

The court held that Colorado's common-law collateral-source rule bars admission at trial of amounts paid by an insurer for a plaintiff's medical expenses, even when offered to prove the reasonable value of those services. The statute abrogated only the post-verdict setoff component of the rule and did not clearly eliminate its pre-verdict evidentiary component. The court therefore affirmed the court of appeals' order vacating the damages judgment and remanding for a new damages trial. Justice Eid, joined by Justices Coats and Boatright, dissented, reasoning that the amount accepted by medical providers was relevant to reasonable value and could be admitted without identifying the payer.