Procedural Challenges to House Bill 837 in Personal Injury Cases
FLWSUPP 3208STEI
Torts – Automobile Accident – Damages – Past and Future Medical Expenses – Procedural vs. Substantive Law Debate
2nd Judicial Circuit, Gadsden County, November 20, 2024
Case No. 2023-CA-482
Judge: David Frank
This case examines the intersection of legislative changes and judicial procedures in a negligence action arising from a 2019 automobile accident. The defendants, citing House Bill 837 (HB 837), sought to limit evidence of medical expenses presented by the plaintiffs, including past and future medical costs, to amounts derived from statutorily defined formulas.
Case Overview
Karen P. Steiger, individually and as guardian of D.C.P., sued the defendants for damages following a vehicle collision. The defendants filed a motion in limine based on HB 837, specifically Florida Statute 768.0427, which governs the admissibility of evidence related to medical treatment costs. They requested the court to limit evidence of medical charges to “statutorily determined amounts” and exclude higher charges.
The court denied the motion, determining that the relevant subsections of HB 837 are procedural in nature and intrude upon the Florida Supreme Court’s exclusive rule-making authority.
Defendants’ Motion and Argument
- Statutory Basis
- Defendants relied on Florida Statute 768.0427, enacted under HB 837, which limits evidence of medical charges to specific formulas based on Medicare and Medicaid rates, and restricts future medical expenses to amounts determined by existing or potential insurance coverage.
- Request for Court Determination
- Defendants sought a pre-trial determination of reasonable medical charges and an order barring plaintiffs from presenting evidence of charges exceeding statutory amounts.
Court’s Analysis and Rulings
- Substantive vs. Procedural Law
- The court found the provisions of HB 837 procedural, affecting the admissibility of evidence rather than creating or altering substantive rights. Under Article V, Section 2(a) of the Florida Constitution, procedural matters fall exclusively within the Florida Supreme Court’s authority.
- Precedent on Collateral Sources
- The court cited Florida Supreme Court rulings prohibiting the admission of collateral source benefits (e.g., insurance payments) as evidence during trial. Instead, such benefits are addressed post-trial as setoffs.
- Impact on Plaintiffs’ Evidence
- Plaintiffs are entitled to present evidence of the full amount of their medical bills, with defendants permitted to challenge the reasonableness of those charges using comparative evidence from other providers. The statutory provisions do not override this established procedural rule.
- Future Medical Expenses
- The court deemed speculative any effort to calculate future medical costs based on potential insurance coverage or Medicare/Medicaid rates. Such speculation could lead to “trials within trials,” detracting from the primary focus of litigation.
Conclusion
The court denied the defendants’ motion in limine, preserving plaintiffs’ ability to present evidence of actual medical charges while allowing defendants to contest their reasonableness. It emphasized the importance of addressing collateral source adjustments post-trial to maintain fairness and consistency with established procedural law.
Key Takeaway:
This case underscores the judicial limitations on legislative attempts to alter procedural rules governing evidence in personal injury cases. Courts must harmonize legislative directives with existing rules to ensure they do not infringe upon constitutional principles.
Today’s Insight:
“Justice delayed is justice denied.”