Scott v. Garfield, 454 Mass. 790 (2009)

Citation: Scott v. Garfield, 454 Mass. 790 (2009)
Parent Document: Scott v. Garfield, 454 Mass. 790 (2009)
Jurisdiction: Massachusetts (state)
Effective Date: 2009-09-15
Original Source: https://www.courtlistener.com/opinion/6580039/scott-v-garfield/ ↗

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The Indiana court adopted a similar approach in Stanley v. Walker, supra. The court first noted that under its rules of evidence, “[statements of charges” for medical expenses were admissible and constituted “prima facie evidence that the charges are reasonable.” Id. at 856. The court went on to cite recent studies of hospital charge structures, operations and payments, concluding that “ [currently, the relationship between charges and costs is ‘tenuous at best,’ ” and that the “complexities of health care pricing structures make it difficult to determine whether the amount paid, the amount billed, or an amount in between represents the reasonable value of medical services.” Id. at 857. As a consequence, the court held that both the original bill and the amount accepted are evidence relevant to determining the reasonable value of medical expenses and are admissible as such. Id. at 858.6

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