## Facts

- Jean Dedmon was injured in an automobile collision and sued the alleged tortfeasor, John T. Cook, for negligence, seeking damages including past and future medical expenses.
- After Cook died, the co-personal representatives of his estate, Debbie Steelman and Danny T. Cates, Sr., were substituted as defendants.
- Dedmon’s medical providers billed a total of $52,482.87 in undiscounted charges.
- Dedmon’s private health insurer paid reduced, contractually discounted amounts totaling about $18,255.42, which providers accepted as payment in full.
- Defendants moved in limine to exclude evidence of the full, undiscounted bills, arguing that “reasonable” medical expenses should be limited to the discounted amounts accepted from the insurer.
- The trial court granted the motion, limiting proof of medical expenses to the discounted amounts.
- The intermediate appellate court concluded the full bills were admissible to show reasonableness and suggested defendants could introduce discounted amounts as rebuttal without referencing insurance.
- The Tennessee Supreme Court granted review to determine whether a prior decision interpreting “reasonable charges” under the Hospital Lien Act governed personal-injury damages and how the collateral source rule affected admissibility of insurance discounts.

## Issues

1. Whether a prior decision construing “reasonable charges” under the Hospital Lien Act applies to the determination of reasonable medical expenses in personal-injury actions.
2. Whether, in a personal-injury action involving private health-insurance discounts, the collateral source rule permits the plaintiff to introduce undiscounted medical bills and bars the defendant from introducing evidence of discounted amounts accepted from the insurer.

## Decision

- The court held that the earlier Hospital Lien Act decision did not control the measure or proof of medical expenses in personal-injury cases.
- The court held that Tennessee’s collateral source rule applies to private health-insurance benefits and related provider discounts in personal-injury litigation.
- Plaintiffs may introduce the full, undiscounted medical bills as prima facie evidence of reasonable medical expenses.
- Defendants may not introduce evidence of the discounted rates accepted from the plaintiff’s insurer to rebut the reasonableness of the billed charges because that would contravene the collateral source rule.
- The court affirmed in part and reversed in part the intermediate appellate decision and remanded for further proceedings.

## Legal Principles

- Interpretation of “reasonable charges” under the Hospital Lien Act is confined to that statute and does not redefine “reasonable medical expenses” recoverable as tort damages.
- Under the collateral source rule, a tortfeasor may not reduce liability by introducing evidence that the plaintiff received benefits from sources independent of the tortfeasor, including private insurance.
- Full, undiscounted medical bills are admissible as prima facie evidence of the reasonableness of medical charges in a personal-injury case; the defendant bears the burden of rebuttal.
- Rebuttal of medical-expense reasonableness is permitted only through competent evidence that does not disclose or depend upon collateral-source payments or discounts (e.g., evidence addressing market rates, necessity, or customary charges without invoking insurance benefits).

## Conclusion

The court reaffirmed that private-insurance discounts are collateral-source benefits in Tennessee personal-injury cases: a plaintiff may prove medical-expense damages with full billed charges, and a defendant may not use insurer-negotiated discounts to reduce or rebut those damages, though other non-collateral rebuttal evidence remains available.


Dedmon v. Steelman, 535 S.W.3d 431 (Tenn. 2017)