Rodriguez v. Diede
Rodriguez v. Diede, 2025 UT App 68 (Luthy, J.)
Civil
The Utah Court of Appeals held:
- References at trial to Plaintiffs’ use of medical liens and other credit financing did not violate the collateral source rule because Defendant used that evidence for the legitimate purpose of showing potential bias or bad faith.
- Practice tip: When a jury is explicitly informed that a plaintiff has received collateral source benefits, repeated references to the absence of any significant out-of-pocket medical expenses violate the collateral source rule. But when a jury is merely informed that a plaintiff obtained credit financing but remains ultimately responsible for the expenses, the collateral source rule is not violated.