collateral source rule (Maine) · Go Syfert
← Maine issues

collateral source rule in Maine

17 Maine opinions name it 2 courts 1978–2022 2 in the last five years

The cases below were cited by Maine courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Werner v. Lanegreen
me · 1978 · cited in 10 Maine opinions naming this issue, 1987–2022
2 sentences

2022The price reduction resulting from the write-off is a benefit analogous to the free medical care in Werner, 393 A.2d at 1335 , which should inure to Plaintiff under the collateral source rule.

2016The collateral source rule provides that, "if a plaintiff is compensated in whole or in part for his damages by some source independent of the tortfeasor, he is still permitted to have a full recovery against the tortfeasor." Werner v. Lane, 393 A.2d 1329, 1335 (Me. 1978).

1010
Potvin v. Seven Elms, Inc.green
me · 1993 · cited in 5 Maine opinions naming this issue, 1995–2016
2 sentences

1995The applicable law governing the instant case was clearly stated by the Court in Potvin v. Seven Elms, Inc., 628 A.2d 115 (Me.1993): We have previously held that under the collateral source rule, a plaintiff who has *676 been compensated in whole or in part for his damages by a source independent of the tortfeasor is nevertheless entitled to a full recovery against the tortfeasor.

1995The applicable law governing the instant ease was clearly stated by the Court in Potvin v. Seven Elms, Inc., 628 A.2d 115 (Me.1993): We have previously held that under the collateral source rule, a plaintiff who has been compensated in whole or in part for his damages by a source independent of the tortfeasor is nevertheless entitled to a full recovery against the tortfeasor.

55
Albert E. DAVIDSON, Plaintiff, Appellee, v. Louis W. SULLIVAN, M.D., Secretary of Health and Human Services, Defendant, Appellantgreen
ca1 · 1991 · cited in 1 Maine opinions naming this issue, 2014–2014
1 sentence

2014S.M.F. <][ 43 9 .) Under federal law, an SSDI beneficiary who also receives workers' compensation benefits under state law cannot receive more than 80% of her "average current earnings." 10 42 U.S.C. § 424a(a)(5) (2013); see also Davidson v. Sullivan, 942 F.2d 90, 92 (1st Cir. 1991) ("Where an individual receives both worker's compensation benefits and social security benefits, the total benefits received may not exceed eighty percent of his predisability income.") 8 Plaintiff argues the collateral source rule prevents the court from considering the SSDI payments.

11
Hoitt v. Hallgreen
me · 1995 · cited in 1 Maine opinions naming this issue, 2004–2004
2 sentences

2004The collateral source doctrine provides that “a plaintiff who has received compensation for her damages from sources independent of the tortfeasor remains entitled to a full recovery.” Hoitt v. Hall, 661 A.2d 669, 673 (Me.1995).

2004The collateral source doctrine provides that “a plaintiff who has received compensation for her damages from sources independent of the tortfeasor remains entitled to a full recovery.” Hoitt v. Hall, 661 A.2d 669, 673 (Me.1995).

11
Stubbs v. Bartlettgreen
me · 1984 · cited in 1 Maine opinions naming this issue, 1987–1987
1 sentence

1987Werner v. Lane, 393 A.2d 1329, 1335-36 (Me.1978); Stubbs v. Bartlett, 478 A.2d 690, 694 (Me.1984); Maine Human Rights Commission v. Department of Corrections, 474 A.2d 860, 870 (Me.1984).

11
Maine Human Rights Commission Ex Rel. Kellman v. Department of Correctionsgreen
me · 1984 · cited in 1 Maine opinions naming this issue, 1987–1987
1 sentence

1987Werner v. Lane, 393 A.2d 1329, 1335-36 (Me.1978); Stubbs v. Bartlett, 478 A.2d 690, 694 (Me.1984); Maine Human Rights Commission v. Department of Corrections, 474 A.2d 860, 870 (Me.1984).

11
Daniels v. Celestegreen
mass · 1939 · cited in 1 Maine opinions naming this issue, 1978–1978
2 sentences

1978See Daniels v. Celeste, 303 Mass. 148 , 21 N.E.2d 1 , 128 A.L.R. 682 (1939); McKay v. Town of West Seneca, 51 A.D.2d 373 , 381 N.Y.S.2d 892 (1976). 4 Among the various rationales advanced in support of the collateral source rule, we find the foregoing most persuasive: “The philosophy underlying the Collateral Source Rule seems to be that either the injured party or the tortfeasor is going to receive a windfall, if a part of the pecuniary loss is paid for by an outside *1336 source and that it is more just that the windfall should inure to the benefit of the injured party than that it should ac

1978See Daniels v. Celeste, 303 Mass. 148 , 21 N.E.2d 1 , 128 A.L.R. 682 (1939); McKay v. Town of West Seneca, 51 A.D.2d 373 , 381 N.Y.S.2d 892 (1976). 4 Among the various rationales advanced in support of the collateral source rule, we find the foregoing most persuasive: “The philosophy underlying the Collateral Source Rule seems to be that either the injured party or the tortfeasor is going to receive a windfall, if a part of the pecuniary loss is paid for by an outside *1336 source and that it is more just that the windfall should inure to the benefit of the injured party than that it should ac

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maine. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Grover v. Boise Cascade Corp. green
me · 2004
2 sentences

2019An error is obvious only when it "constitutes such a serious injustice that reversal is necessary because we could not in good conscience let the judgment stand." Coyne v. Peace , 2004 ME 150 , ¶ 14, 863 A.2d 885 . [¶22] The collateral source doctrine typically precludes the admission of evidence of workers' compensation because "a plaintiff who has received compensation for [his] damages from sources independent of the tortfeasor remains entitled to a full recovery [from the tortfeasor]." Grover v. Boise Cascade Corp. , 2004 ME 119 , ¶ 24, 860 A.2d 851 (quotation marks omitted).

2019An error is obvious only when it "constitutes such a serious injustice that reversal is necessary because we could not in good conscience let the judgment stand." Coyne v. Peace , 2004 ME 150 , ¶ 14, 863 A.2d 885 . [¶22] The collateral source doctrine typically precludes the admission of evidence of workers' compensation because "a plaintiff who has received compensation for [his] damages from sources independent of the tortfeasor remains entitled to a full recovery [from the tortfeasor]." Grover v. Boise Cascade Corp. , 2004 ME 119 , ¶ 24, 860 A.2d 851 (quotation marks omitted).

22019–2019
Coyne v. Peace green
me · 2004
2 sentences

2019An error is obvious only when it "constitutes such a serious injustice that reversal is necessary because we could not in good conscience let the judgment stand." Coyne v. Peace , 2004 ME 150 , ¶ 14, 863 A.2d 885 . [¶22] The collateral source doctrine typically precludes the admission of evidence of workers' compensation because "a plaintiff who has received compensation for [his] damages from sources independent of the tortfeasor remains entitled to a full recovery [from the tortfeasor]." Grover v. Boise Cascade Corp. , 2004 ME 119 , ¶ 24, 860 A.2d 851 (quotation marks omitted).

2019An error is obvious only when it "constitutes such a serious injustice that reversal is necessary because we could not in good conscience let the judgment stand." Coyne v. Peace , 2004 ME 150 , ¶ 14, 863 A.2d 885 . [¶22] The collateral source doctrine typically precludes the admission of evidence of workers' compensation because "a plaintiff who has received compensation for [his] damages from sources independent of the tortfeasor remains entitled to a full recovery [from the tortfeasor]." Grover v. Boise Cascade Corp. , 2004 ME 119 , ¶ 24, 860 A.2d 851 (quotation marks omitted).

22019–2019
Commonwealth v. Silver green
pasuperct · 1978
1 sentence

2008Werner v. Lane, 393 A. 2d 1239 (Me. 1978).

12008–2008
Claim of McKay v. Town of West Seneca green
nyappdiv · 1976
2 sentences

1978See Daniels v. Celeste, 303 Mass. 148 , 21 N.E.2d 1 , 128 A.L.R. 682 (1939); McKay v. Town of West Seneca, 51 A.D.2d 373 , 381 N.Y.S.2d 892 (1976). 4 Among the various rationales advanced in support of the collateral source rule, we find the foregoing most persuasive: “The philosophy underlying the Collateral Source Rule seems to be that either the injured party or the tortfeasor is going to receive a windfall, if a part of the pecuniary loss is paid for by an outside *1336 source and that it is more just that the windfall should inure to the benefit of the injured party than that it should ac

1978See Daniels v. Celeste, 303 Mass. 148 , 21 N.E.2d 1 , 128 A.L.R. 682 (1939); McKay v. Town of West Seneca, 51 A.D.2d 373 , 381 N.Y.S.2d 892 (1976). 4 Among the various rationales advanced in support of the collateral source rule, we find the foregoing most persuasive: “The philosophy underlying the Collateral Source Rule seems to be that either the injured party or the tortfeasor is going to receive a windfall, if a part of the pecuniary loss is paid for by an outside *1336 source and that it is more just that the windfall should inure to the benefit of the injured party than that it should ac

11978–1978
Acme-Evans Co. v. Schnepf green
indctapp · 1938
2 sentences

1978Without characterizing its ruling as an application of the collateral source rule, this Court in a tort action for injuries to his minor child has permitted recovery by the father of the reasonable value of necessary nursing services rendered gratuitously by the mother, quoting with approval the language of Acme-Evans Co. v. Schnepf, 105 Ind.App. 475 , 15 N.E.2d 742 (1938): “ ‘If [plaintiff] is fortunate enough to secure the services of his wife in treating the injuries of their minor son, rather - than employing one who is not a member of the family and thus obligating himself to pay for such

1978Without characterizing its ruling as an application of the collateral source rule, this Court in a tort action for injuries to his minor child has permitted recovery by the father of the reasonable value of necessary nursing services rendered gratuitously by the mother, quoting with approval the language of Acme-Evans Co. v. Schnepf, 105 Ind.App. 475 , 15 N.E.2d 742 (1938): “ ‘If [plaintiff] is fortunate enough to secure the services of his wife in treating the injuries of their minor son, rather - than employing one who is not a member of the family and thus obligating himself to pay for such

11978–1978
Wells v. Minneapolis Baseball & Athletic Ass'n green
minn · 1913
2 sentences

1978Accord: Wells v. Minneapolis B. & A. Ass’n, 122 Minn. 327 , 142 N.W. 706 , 46 L.R.A.,N.S., 606, Ann.Cas.1914D, 922 (1913).

1978Accord: Wells v. Minneapolis B. & A. Ass’n, 122 Minn. 327 , 142 N.W. 706 , 46 L.R.A.,N.S., 606, Ann.Cas.1914D, 922 (1913).

11978–1978
Johnson v. Rhuda green
me · 1960
2 sentences

1978Without characterizing its ruling as an application of the collateral source rule, this Court in a tort action for injuries to his minor child has permitted recovery by the father of the reasonable value of necessary nursing services rendered gratuitously by the mother, quoting with approval the language of Acme-Evans Co. v. Schnepf, 105 Ind.App. 475 , 15 N.E.2d 742 (1938): “ ‘If [plaintiff] is fortunate enough to secure the services of his wife in treating the injuries of their minor son, rather - than employing one who is not a member of the family and thus obligating himself to pay for such

1978Without characterizing its ruling as an application of the collateral source rule, this Court in a tort action for injuries to his minor child has permitted recovery by the father of the reasonable value of necessary nursing services rendered gratuitously by the mother, quoting with approval the language of Acme-Evans Co. v. Schnepf, 105 Ind.App. 475 , 15 N.E.2d 742 (1938): “ ‘If [plaintiff] is fortunate enough to secure the services of his wife in treating the injuries of their minor son, rather - than employing one who is not a member of the family and thus obligating himself to pay for such

11978–1978
Moulton v. Groveton Papers Co. green
nh · 1974
2 sentences

1978For the pros and cons respecting the rule, turn to Moulton v. Groveton Papers Company, 114 N.H. 505 , 323 A.2d 906 (1974).

1978For the pros and cons respecting the rule, turn to Moulton v. Groveton Papers Company, 114 N.H. 505 , 323 A.2d 906 (1974).

11978–1978

Where else courts name it

CA 138 (1967–2026) IL 105 (1973–2026) LA 97 (1977–2025) TX 86 (1969–2026) OH 64 (1966–2023) GA 62 (1970–2025) PA 55 (1971–2024) NY 53 (1962–2026) FL 52 (1968–2026) CO 52 (1971–2026) MO 47 (1968–2023) WI 46 (1972–2026) WA 45 (1978–2024) NJ 42 (1968–2025) VA 38 (1986–2023) AZ 37 (1967–2025) CT 34 (1970–2021) SC 32 (1967–2025) MD 28 (1968–2022) MI 28 (1973–2019) AL 28 (1977–2025) MA 24 (1974–2024) MS 24 (1981–2023) DE 23 (1964–2026) AR 22 (1972–2017) WV 22 (1973–2025) KS 22 (1982–2019) IA 20 (1974–2019) NM 20 (1974–2024) KY 18 (1974–2025) NC 18 (1982–2021) MN 17 (1980–2016) ME 17 (1978–2022) RI 16 (1966–2013) TN 15 (1994–2025) OK 15 (1977–2023) IN 15 (1971–2015) OR 14 (1972–2026) NV 12 (1996–2024) VT 11 (1983–2024) NE 11 (1989–2019) AK 10 (1967–2022) UT 10 (1997–2026) DC 10 (1978–2024) SD 8 (1975–2009) MT 8 (1972–2000) WY 7 (1986–2002) HI 7 (1999–2025) NH 6 (1980–2018) ND 4 (1978–1999) ID 4 (1979–1991)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check