Supreme Court of Delaware

Diane L. Stayton, Plaintiff Below-Appellant v. Delaware Health Corporation, a Delaware Corporation; Harbor…

June 12, 20152015 Del. LEXIS 288

Summary

The Court affirmed the limitation of Stayton's medical-expense damages to the amount Medicare paid her healthcare providers. It held that the collateral source rule does not apply to amounts providers are legally required to write off for Medicare patients, and that the Medicare payment conclusively establishes the recoverable reasonable value of those services. Chief Justice Strine, concurring, agreed with the result but emphasized broader fairness, deterrence, and healthcare-cost concerns supporting refusal to extend the collateral source rule.