Goodbye Collateral Source Rule.

The California Supreme Court stated the collateral source rule, as outlined in Helfend v. Southern Cal. Rapid Transit District (1970) 2 Cal.3d 1, [465 P.2d 61; 84 Cal.Rptr. 173] has no bearing on amounts that were included in a medical provider’s bill for which a plaintiff never incurred liability because the provider, by prior agreement, accepted a lesser amount as full payment.  Howell v. Hamilton Meats & Provisions, Inc.   (Cal. Sup. Ct.; August 18, 2011) 52 Cal.4th 541, [257 P.3d 1130; 129 Cal.Rptr.3d 325].