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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¶34 The same is true here. Evidence that, on average, a procedure costs less than the amount charged or that Gerlach's physicians accept a lesser payment for services from Medicare is not helpful to the jury in determining whether her medical expenses were reasonable. Furthermore, Gerlach met her burden to prove the reasonableness of her medical expenses under Patterson because she presented expert testimony other than the medical records and bills themselves. Dr. Lowell Finkleman testified that the medical treatment Gerlach received and the resulting charges were reasonable and customary for this community and consistent with charges he had seen over the years. Therefore, the trial court did not abuse its discretion by refusing to allow Dr. Wickizer to testify.

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