## Facts

- A minor passenger, Bruce Hueper, was seriously injured in a collision between a truck driven by Emil Hueper (owned by Arland Gregor) and a truck driven by John M. Neubauer (owned by Dean Goodrich).
- Bruce, through his mother and guardian Sharon Hueper, sued Goodrich and Neubauer for personal injuries; Goodrich and Neubauer impleaded Gregor and Emil Hueper for contribution/indemnity.
- Bruce’s parents, Emil and Sharon Hueper, also sued Goodrich and Neubauer to recover Bruce’s medical expenses.
- The case was bifurcated: a jury tried liability first, and damages were tried later.
- Much of Bruce’s hospital care was provided by a charitable hospital without billing the family or accepting insurance proceeds for those services.
- At the damages phase, the trial court allowed recovery of the reasonable value of medical care, including the value of hospital services furnished without charge, and barred evidence that the hospital services were gratuitous.
- The trial court also awarded interest on the defendants’ liability insurance policy amount from the date of the liability trial rather than from the later damages judgment.

## Issues

1. Whether the collateral source rule permits recovery of the reasonable value of necessary medical and hospital services furnished without charge by a charitable institution, and bars evidence of the gratuitous nature of those services.
2. Whether, in a bifurcated liability/damages trial, interest may be awarded on the defendants’ insurance policy limits from the date of the liability verdict rather than from the judgment fixing damages.

## Decision

- The Minnesota Supreme Court affirmed the award permitting the father to recover the reasonable value of Bruce’s medical expenses, including charitable hospital services provided without charge.
- The court held evidence that the hospital did not bill for the services was properly excluded under the collateral source rule.
- The court reversed the award of interest from the date of the liability trial on the insurance policy limits.
- The disposition was affirmed in part and reversed in part.

## Legal Principles

- Damages for medical care are measured by the reasonable value of necessary services caused by the tort, not by whether the plaintiff paid for the services.
- Gratuitous medical or hospital services provided by a charitable source are collateral benefits; the tortfeasor may not reduce damages by showing the plaintiff received such services without charge.
- In bifurcated proceedings, interest generally does not run on amounts not yet fixed or ascertainable; awarding interest from a liability determination is improper when damages are determined later by judgment.

## Conclusion

The court held that charitable hospital care is a collateral source and does not reduce a tortfeasor’s liability for the reasonable value of medical services, but it rejected interest calculated from the earlier liability verdict because damages were not established until the later judgment.


Hueper v. Goodrich, 314 N.W.2d 828 (Minn. 1982)