Martin J. Coyne v. William T. Campbell

Summary

The Court of Appeals affirmed the trial court's ruling that a plaintiff cannot recover the reasonable value of medical and nursing services rendered gratuitously, reaffirming the longstanding Drinkwater rule that only pecuniary losses actually paid or owed are recoverable. The dissent argued that the collateral source doctrine should allow recovery of such gratuitous services, while the concurrence agreed with the majority.