collateral source rule (Montana) · Go Syfert
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collateral source rule in Montana

8 Montana opinions name it 1 courts 1972–2000 0 in the last five years

The cases below were cited by Montana 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 (4)

CaseFollowedCited
Goggans v. Winkleygreen
mont · 1972 · cited in 3 Montana opinions naming this issue, 1986–2000
2 sentences

2000See also Thomsen v. State, Dept. of Highways (1992), 253 Mont. 460 , 833 P.2d 1076 (in a personal injury action, admission of evidence concerning availability of medical and rehabilitation services for plaintiff from the Veterans Administration was error); Allers v. Willis (1982), 197 Mont. 499 , 643 P.2d 592 (the fact that plaintiff, who was injured in an automobile accident, had a pending workers’ compensation claim was inadmissible); Goggans v. Winkley (1972), 159 Mont. 85, 91 , 495 P.2d 594, 598 (“Injection of collateral matters involving transactions between others, which are in this case

2000See also Thomsen v. State, Dept. of Highways (1992), 253 Mont. 460 , 833 P.2d 1076 (in a personal injury action, admission of evidence concerning availability of medical and rehabilitation services for plaintiff from the Veterans Administration was error); Allers v. Willis (1982), 197 Mont. 499 , 643 P.2d 592 (the fact that plaintiff, who was injured in an automobile accident, had a pending workers’ compensation claim was inadmissible); Goggans v. Winkley (1972), 159 Mont. 85, 91 , 495 P.2d 594, 598 (“Injection of collateral matters involving transactions between others, which are in this case

13
McWilliams v. Clemgreen
mont · 1987 · cited in 1 Montana opinions naming this issue, 2000–2000
2 sentences

2000See McWilliams v. Clem (1987), 228 Mont. 297, 309 , 743 P.2d 577, 585 (concluding that bonding company payment should be deducted from total amount of damages where notary is joint tortfeasor). ¶63 Five U’s, Inc. does, however, provide the collateral source rule, which is applicable on principle here.

2000See McWilliams v. Clem (1987), 228 Mont. 297, 309 , 743 P.2d 577, 585 (concluding that bonding company payment should be deducted from total amount of damages where notary is joint tortfeasor). ¶63 Five U’s, Inc. does, however, provide the collateral source rule, which is applicable on principle here.

11
Thomsen v. State Ex Rel. Department of Highwaysgreen
mont · 1992 · cited in 1 Montana opinions naming this issue, 2000–2000
2 sentences

2000See also Thomsen v. State, Dept. of Highways (1992), 253 Mont. 460 , 833 P.2d 1076 (in a personal injury action, admission of evidence concerning availability of medical and rehabilitation services for plaintiff from the Veterans Administration was error); Allers v. Willis (1982), 197 Mont. 499 , 643 P.2d 592 (the fact that plaintiff, who was injured in an automobile accident, had a pending workers’ compensation claim was inadmissible); Goggans v. Winkley (1972), 159 Mont. 85, 91 , 495 P.2d 594, 598 (“Injection of collateral matters involving transactions between others, which are in this case

2000See also Thomsen v. State, Dept. of Highways (1992), 253 Mont. 460 , 833 P.2d 1076 (in a personal injury action, admission of evidence concerning availability of medical and rehabilitation services for plaintiff from the Veterans Administration was error); Allers v. Willis (1982), 197 Mont. 499 , 643 P.2d 592 (the fact that plaintiff, who was injured in an automobile accident, had a pending workers’ compensation claim was inadmissible); Goggans v. Winkley (1972), 159 Mont. 85, 91 , 495 P.2d 594, 598 (“Injection of collateral matters involving transactions between others, which are in this case

11
Christine H. Patterson v. Norfolk and Western Railway Company, a Foreign Corporationgreen
ca6 · 1973 · cited in 1 Montana opinions naming this issue, 1985–1985
1 sentence

1985See generally Patterson v. Norfolk and Western Railway Co. (6th Cir. 1973), 489 F.2d 303 ; Blake v. Delaware and Hudson Railway Co. (2nd Cir. 1973), 484 F.2d 204 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
Hrnjak v. Graymar, Inc. green
cal · 1971
2 sentences

2000Admission despite such ominous potential should be permitted only upon such persuasive showing that the evidence sought to be introduced is of substantial probative value. [Emphasis added.] Thomsen, 253 Mont. at 463 , 833 P.2d at 1078 (quoting Hrnjak v. Graymar, Inc. (1971), 4 Cal.3d 725 , 94 Cal.Rptr. 623 , 484 P.2d 599, 604 ). ¶ 39 Additionally, this Court held in Mydlarz that it was reversible error for a district court to admit evidence that a plaintiff had received workers' compensation benefits.

2000Admission despite such ominous potential should be permitted only upon such persuasive showing that the evidence sought to be introduced is of substantial probative value. [Emphasis added.] Thomsen, 253 Mont. at 463 , 833 P.2d at 1078 (quoting Hrnjak v. Graymar, Inc. (Cal. 1971), 484 P.2d 599, 604 ). ¶39 Additionally, this Court held in Mydlarz that it was reversible error for a district court to admit evidence that a plaintiff had received workers’ compensation benefits.

21992–2000
Allers v. Willis green
mont · 1982
2 sentences

2000See also Thomsen v. State, Dept. of Highways (1992), 253 Mont. 460 , 833 P.2d 1076 (in a personal injury action, admission of evidence concerning availability of medical and rehabilitation services for plaintiff from the Veterans Administration was error); Allers v. Willis (1982), 197 Mont. 499 , 643 P.2d 592 (the fact that plaintiff, who was injured in an automobile accident, had a pending workers’ compensation claim was inadmissible); Goggans v. Winkley (1972), 159 Mont. 85, 91 , 495 P.2d 594, 598 (“Injection of collateral matters involving transactions between others, which are in this case

2000See also Thomsen v. State, Dept. of Highways (1992), 253 Mont. 460 , 833 P.2d 1076 (in a personal injury action, admission of evidence concerning availability of medical and rehabilitation services for plaintiff from the Veterans Administration was error); Allers v. Willis (1982), 197 Mont. 499 , 643 P.2d 592 (the fact that plaintiff, who was injured in an automobile accident, had a pending workers’ compensation claim was inadmissible); Goggans v. Winkley (1972), 159 Mont. 85, 91 , 495 P.2d 594, 598 (“Injection of collateral matters involving transactions between others, which are in this case

12000–2000
Tribby v. Northwestern Bank of Great Falls green
mont · 1985
2 sentences

1998Tribby v. Northwestern Bank of Great Falls (1985), 217 Mont. 196, 209 , 704 P.2d 409, 417 .

1998Tribby v. Northwestern Bank of Great Falls (1985), 217 Mont. 196, 209 , 704 P.2d 409, 417 .

11998–1998
Butte Community Union v. Lewis green
mont · 1986
2 sentences

1994Butte Community Union v. Lewis (1986), 219 Mont. 426, 430 , 712 P.2d 1309, 1311 .

1994Butte Community Union v. Lewis (1986), 219 Mont. 426, 430 , 712 P.2d 1309, 1311 .

11994–1994
Edward W. Blake v. Delaware and Hudson Railway Company green
ca2 · 1973
1 sentence

1985See generally Patterson v. Norfolk and Western Railway Co. (6th Cir. 1973), 489 F.2d 303 ; Blake v. Delaware and Hudson Railway Co. (2nd Cir. 1973), 484 F.2d 204 .

11985–1985
Burk Royalty Company v. Jacobs green
okla · 1963
1 sentence

1972In the Oklahoma case, Burk Royalty Company v. Jacobs, (Okl.1963), 387 P.2d 638, 640 , the landowners brought action against oil and gas lessee for damages to surface of land by salt water and oil pollution.

11972–1972

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.

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