In a decision to provide more clarity regarding plaintiff’s special damages, on March 8, 2012, California’s Second District Court of Appeals issued its opinion in Sanchez v. Brooke, 204 Cal.App.4th 126 (2012). In its ruling, the Court extends the rationale and holding in Howell v. Hamilton Meats & Provisions, Inc. (2011) 52 Cal.4th 541, to preclude plaintiff from recovering as a damage past medical expenses paid to providers accepting a discounted amount as payment in full from an employer under the Workers’ Compensation law. For details, please click here.
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