Gerlach v. Cove Apartments, LLC, 446 P.3d 624 (2019)

Citation: Gerlach v. Cove Apartments, LLC, 446 P.3d 624 (2019)
Parent Document: Gerlach v. Cove Apartments, LLC, 446 P.3d 624 (2019)
Jurisdiction: Washington (state)
Effective Date: 2019-05-13
Original Source: https://www.courtlistener.com/opinion/6659245/gerlach-v-cove-apartments-llc/ ↗

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*633*828¶31 A plaintiff "may recover only the reasonable value of medical services received, not the total of all bills paid." Patterson v. Horton, 84 Wash. App. 531, 543, 929 P.2d 1125 (1997). "Thus, the plaintiff must prove that medical costs were reasonable and, in doing so, cannot rely solely on medical records and bills." Patterson, 84 Wash. App. at 543, 929 P.2d 1125. "In other words, medical records and bills are relevant to prove past medical expenses only if supported by additional evidence that the treatment and the bills were both necessary and reasonable." Patterson, 84 Wash. App. at 543, 929 P.2d 1125.

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