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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¶33 The trial court properly excluded Dr. Wickizer's testimony. Evidence of what Gerlach's physicians accept from Medicaid and how the inpatient charges are affected by Dr. Wickizer's cost-to-charge ratio is not proof that Gerlach's medical expenses were unreasonable. In Hayes v. Wieber Enterprises, Inc., 105 Wash. App. 611, 616, 20 P.3d 496 (2001), the Court of Appeals held that the trial court did not *829abuse its discretion in refusing to admit evidence of the amount a plaintiff's doctor actually accepted as payment from the insurance company to refute the reasonableness of the billed medical expenses. It reasoned that "[t]he fact that the doctor accepted the first party insurance carrier's limit for his services does not tend to prove his charge for these services was unreasonable." Hayes, 105 Wash. App. at 616, 20 P.3d 496.

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