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

7 Wyoming opinions name it 1 courts 1986–2002 0 in the last five years

The cases below were cited by Wyoming 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
Helfend v. Southern California Rapid Transit Districtgreen
cal · 1970 · cited in 2 Wyoming opinions naming this issue, 1995–1995
2 sentences

1995This may be actually consistent with the rule in California because, in Helfend , the court declined to expand the application of the collateral source rule, stating: "Double recovery is justified only in the face of some exceptional, supervening reason, as in the case of accident or life insurance, where it is felt unjust that the tortfeasor should take advantage of the thrift and prescience of the victim in having paid the premiums." Helfend, 465 P.2d at 67 (emphasis added).

1995This may be actually consistent with the rule in California because, in Hel-fend, the court declined to expand the application of the collateral source rule, stating: “Double recovery is justified only in the face of some exceptional, supervening reason, as in the case of accident or life insurance, where it is felt unjust that the tortfeasor should take advantage of the thrift and prescience of the victim in having paid the premiums.” Helfend, 465 P.2d at 67 (emphasis added).

22
Banks v. Crownergreen
wyo · 1985 · cited in 1 Wyoming opinions naming this issue, 2002–2002
2 sentences

2002Carlton v. Carlton, 997 P.2d 1028, 1031 (Wyo.2000); Young , ¶ 6. [¶ 14] In the presentation of this issue, Garnick relies on the case of Banks v. Crowner, 694 P.2d 101, 105 (Wyo.1985), wherein we adopted the collateral source rule: We will now consider whether the hospital bills from the Veteran's Administration (V.A.) were properly submitted to the jury for consideration.

2002Carlton v. Carlton, 997 P.2d 1028, 1031 (Wyo.2000); Young, ¶ 6. [T14] In the presentation of this issue, Garnick relies on the case of Banks v. Crowner, 694 P.2d 101, 105 (Wyo.1985), wherein we adopted the collateral source rule: We will now consider whether the hospital bills from the Veteran's Administration (V.A.) were properly submitted to the jury for consideration.

11
Carlton v. Carltongreen
wyo · 2000 · cited in 1 Wyoming opinions naming this issue, 2002–2002
2 sentences

2002Carlton v. Carlton, 997 P.2d 1028, 1031 (Wyo.2000); Young , ¶ 6. [¶ 14] In the presentation of this issue, Garnick relies on the case of Banks v. Crowner, 694 P.2d 101, 105 (Wyo.1985), wherein we adopted the collateral source rule: We will now consider whether the hospital bills from the Veteran's Administration (V.A.) were properly submitted to the jury for consideration.

2002Carlton v. Carlton, 997 P.2d 1028, 1031 (Wyo.2000); Young, ¶ 6. [T14] In the presentation of this issue, Garnick relies on the case of Banks v. Crowner, 694 P.2d 101, 105 (Wyo.1985), wherein we adopted the collateral source rule: We will now consider whether the hospital bills from the Veteran's Administration (V.A.) were properly submitted to the jury for consideration.

11
Miller v. Campbell Countygreen
wyo · 1995 · cited in 1 Wyoming opinions naming this issue, 1997–1997
1 sentence

1997See Miller v. Campbell County, 901 P.2d 1107, 1112-14 (Wyo.1995). y.

11
Wheatland Irrigation District v. McGuiregreen
wyo · 1977 · cited in 1 Wyoming opinions naming this issue, 1989–1989
1 sentence

1989For a general discussion of the collateral source rule, see Wheatland Irrigation Dist. v. McGuire, 562 P.2d 287, 301-02 (Wyo.1977). .

11
Arneson v. Olsongreen
nd · 1978 · cited in 1 Wyoming opinions naming this issue, 1988–1988
2 sentences

1988Arneson v. Olson, N.D., 270 N.W.2d 125, 131-36 (1978), held its statute unconstitutional because of provisions precluding joinder of parties and severely limiting the doctrine of res ipsa loquitur — provisions not found in the Wyoming statute.

1988Arneson v. Olson, N.D., 270 N.W.2d 125, 131-36 (1978), held its statute unconstitutional because of provisions precluding joinder of parties and severely limiting the doctrine of res ipsa loquitur — provisions not found in the Wyoming statute.

11
Patent Scaffolding Co. v. William Simpson Construction Co.green
calctapp · 1967 · cited in 1 Wyoming opinions naming this issue, 1986–1986
2 sentences

1986As the court stated in Patent Scaffolding Co. v. William Simpson Construction Company, 256 Cal.App.2d 506 , 64 Cal.Rptr. 187, 191 (1967): “ * * * The collateral source rule is punitive; contractual damages are compensatory.

1986As the court stated in Patent Scaffolding Co. v. William Simpson Construction Company, 256 Cal.App.2d 506 , 64 Cal.Rptr. 187, 191 (1967): “ * * * The collateral source rule is punitive; contractual damages are compensatory.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Smith v. County of Los Angeles green
calctapp · 1989
2 sentences

1995Addressing specifically the plaintiff's contention that the collateral source rule should be invoked and, thus, inhibit consideration or deduction of the $110,000 against his award of compensation, the court said: "The first flaw in Forrest's argument is that he cites no authority for the proposition that the collateral source rule applies in an action for inverse condemnation." Smith, 262 Cal.Rptr. at 769 .

1995Addressing specifically the plaintiffs contention that the collateral source rule should be invoked and, thus, inhibit consideration or deduction of the $110,000 against his award of compensation, the court said: “The first flaw in Forrest’s argument is that he cites no authority for the proposition that the collateral source rule applies in an action for inverse condemnation.” Smith, 262 Cal.Rptr. at 769 .

21995–1995
Carson v. Maurer red
nh · 1980
2 sentences

1988In Carson v. Maurer, 120 N.H. 925 , 424 A.2d 825, 830-39 , 12 A.L.R.4th 1 (1980), the statute was held unconstitutional because it provided for periodic payment, abolished the collateral source rule, and required that witnesses for plaintiff be expert in their field — provisions not found in the Wyoming statute.

1988In Carson v. Maurer, 120 N.H. 925 , 424 A.2d 825, 830-39 , 12 A.L.R.4th 1 (1980), the statute was held unconstitutional because it provided for periodic payment, abolished the collateral source rule, and required that witnesses for plaintiff be expert in their field — provisions not found in the Wyoming statute.

11988–1988
Farley v. Engelken green
kan · 1987
2 sentences

1988The specially concurring opinion is premised almost entirely upon a Kansas case, Farley v. Engelken, supra 740 P.2d 1058 , which is not in point, for it considered not the issue presented to us, but "whether the equal protection clause of the Kansas Constitution is violated by the statutory abrogation of the collateral source rule in medical malpractice actions." Three dissenting Kansas Supreme Court justices thought the opinion of the court was not significant, persuasive, thoughtful or provocative.

1988The specially concurring opinion is premised almost entirely upon a Kansas case, Farley v. Engelken, supra 740 P.2d 1058 , which is not in point, for it considered not the issue presented to us, but “whether the equal protection clause of the Kansas Constitution is violated by the statutory abrogation of the collateral source rule in medical malpractice actions.” Three dissenting Kansas Supreme Court justices thought the opinion of the court was not significant, persuasive, thoughtful or provocative.

11988–1988
United Protective Workers Of America, Local No. 2 v. Ford Motor Company green
ca7 · 1955
2 sentences

1986United Protective Workers v. Ford Motor Company, 223 F.2d 49 (7th Cir.1955); and City of Salinas v. Souza & McCue Construction Company, 66 Cal.2d 217 , 57 Cal.Rptr. 337 , 424 P.2d 921 (1967).

1986United Protective Workers v. Ford Motor Company, 223 F.2d 49 (7th Cir.1955); and City of Salinas v. Souza & McCue Construction Company, 66 Cal.2d 217 , 57 Cal. Rptr. 337 , 424 P.2d 921 (1967).

11986–1986
City of Salinas v. Souza & McCue Construction Co. green
cal · 1967
2 sentences

1986United Protective Workers v. Ford Motor Company, 223 F.2d 49 (7th Cir.1955); and City of Salinas v. Souza & McCue Construction Company, 66 Cal.2d 217 , 57 Cal.Rptr. 337 , 424 P.2d 921 (1967).

1986United Protective Workers v. Ford Motor Company, 223 F.2d 49 (7th Cir.1955); and City of Salinas v. Souza & McCue Construction Company, 66 Cal.2d 217 , 57 Cal.Rptr. 337 , 424 P.2d 921 (1967).

11986–1986
Daniel Const. Co. v. INTERN. U. OF OPERATING ENGINEERS green
moed · 1983
2 sentences

1986Daniel Construction Company, Division of Daniel International Corporation v. International Union of Operating Engineers, Local 513, 570 F.Supp. 299 (D.C.Mo.1983); Grover v. Ratliff, 120 Ariz. 368 , 586 P.2d 213 (App.1978); Amos v. Stroud, 252 Ark. 1100 , 482 S.W.2d 592 (1972).

1986Daniel Construction Company, Division of Daniel International Corporation v. International Union of Operating Engineers, Local 513, 570 F. Supp. 299 (D.C.Mo. 1983); Grover v. Ratliff, 120 Ariz. 368 , 586 P.2d 213 (App. 1978); Amos v. Stroud, 252 Ark. 1100 , 482 S.W.2d 592 (1972).

11986–1986
Grover v. Ratliff green
arizctapp · 1978
2 sentences

1986Daniel Construction Company, Division of Daniel International Corporation v. International Union of Operating Engineers, Local 513, 570 F.Supp. 299 (D.C.Mo.1983); Grover v. Ratliff, 120 Ariz. 368 , 586 P.2d 213 (App.1978); Amos v. Stroud, 252 Ark. 1100 , 482 S.W.2d 592 (1972).

1986Daniel Construction Company, Division of Daniel International Corporation v. International Union of Operating Engineers, Local 513, 570 F.Supp. 299 (D.C.Mo.1983); Grover v. Ratliff, 120 Ariz. 368 , 586 P.2d 213 (App.1978); Amos v. Stroud, 252 Ark. 1100 , 482 S.W.2d 592 (1972).

11986–1986
Amos v. Stroud green
ark · 1972
2 sentences

1986Daniel Construction Company, Division of Daniel International Corporation v. International Union of Operating Engineers, Local 513, 570 F.Supp. 299 (D.C.Mo.1983); Grover v. Ratliff, 120 Ariz. 368 , 586 P.2d 213 (App.1978); Amos v. Stroud, 252 Ark. 1100 , 482 S.W.2d 592 (1972).

1986Daniel Construction Company, Division of Daniel International Corporation v. International Union of Operating Engineers, Local 513, 570 F.Supp. 299 (D.C.Mo.1983); Grover v. Ratliff, 120 Ariz. 368 , 586 P.2d 213 (App.1978); Amos v. Stroud, 252 Ark. 1100 , 482 S.W.2d 592 (1972).

11986–1986

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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