In Re Maribel Ronquillo and Martin Cerda v. EcoClean Home Services, Inc. and Jessie Williams

Summary

The court held that a medical finance company was not a collateral source because its lien arrangement did not reduce the injured plaintiff’s financial obligation for medical expenses. It therefore upheld the district court’s determination that evidence concerning the arrangement and medical charges was not excluded under the collateral-source rule, while leaving open whether that evidence could be excluded under other evidentiary rules. The court also concluded that a subsequently enacted statute governing medical-finance liens did not apply to the agreement at issue.