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5 Alabama opinions name it 2 courts 2011–2025 2 in the last five years
The cases below were cited by Alabama 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.
| Case | Followed | Cited |
|---|---|---|
Crocker v. Grammergreen2 sentences2016She also relies on Crocker v. Grammer, 87 So.3d 1190 (Ala. Civ.App.2011), and McCormick v. Bunting, 99 So.3d 1248 (Ala.Civ.App.2012), in which this court held that, in enacting § 12-21-45, Aa.Code 1975, 2 the legislature modified the common-law collateral-source rule in order to allow Alabama juries to determine whether an award of damages should be reduced as the result of payments of medical and hospital expenses made by third parties on behalf of a plaintiff. 2012Discussion In his brief to this court, McCormick states that “the sole issue on appeal is whether the trial court erred by refusing to apply § 12-21-15 and precluding McCormick from presenting evidence that [Bunting’s] medical bills had been paid by a collateral source and the amounts of those payments.” (McCormick’s brief at p. 3.) In Crocker v. Grammer, 87 So.3d 1190, 1193 (Ala.Civ.App.2011), this court held that the legislature had modified the common-law collateral-source rule in order to allow Alabama juries to determine whether an award of damages should be reduced as a result of payment | 3 | 4 |
Senn v. Alabama Gas Corp.green2 sentences2025See Senn v. Alabama Gas Corp., 619 So. 2d 1320, 1325 (Ala. 1993)." Crocker v. Grammer, 87 So. 3d 1190, 1193 (Ala. Civ. 2025See Senn v. Alabama Gas Corp., 619 So. 2d 1320, 1325 (Ala. 1993)." Crocker v. Grammer, 87 So. 3d 1190, 1193 (Ala. Civ. | 3 | 3 |
Williston v. Ardgreen2 sentences2016The common-law collateral-source rule provided “that an amount of damages [was] not decreased by benefits received by a plaintiff [in a personal-injury action] from a source wholly collateral to and independent of the wrongdoer, including services provided by the state at government expense or decreased by institutionalization at government expense.” Williston v. Ard, 611 So.2d 274, 278 (Ala.1992). 2011Under the common-law collateral-source rule, “an amount of damages is not decreased by benefits received by a plaintiff from a source wholly collateral to and independent of the wrongdoer.” Williston v. Ard; 611 So.2d 274, 278 (Ala.1992). | 3 | 3 |
American Legion Post No. 57 v. Leaheygreen1 sentence2011Based on that substantive rule of law, see American Legion Post No. 57 v. Leakey, 681 So.2d 1337, 1343 (Ala.1996), overruled on other grounds by Marsh v. Green, 782 So.2d 223 (Ala.2000) (holding that the collateral-source rule “as a whole is a rule of substantive law,” but one that contains a procedural component (emphasis omitted)), evidence of third-party payments of medical and hospital expenses was not admissible in personal-injury actions because such evidence was irrelevant to the issue of the appropriate measure of damages and unduly prejudicial to the plaintiff if used for other purpos | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Alabama. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Joyce D. Higgs v. Costa Crociere S.P.A. Company
green
2 sentences2025The Higgs court further explained that "[t]he evidentiary role of the collateral source doctrine acts as a 8 SC-2023-0401 and SC-2023-0424 prophylactic, shielding the jury from evidence that is likely to encourage it to violate the substantive role of the rule." Id. at 1314 . 1 Alabama historically applied the common-law collateral-source rule. 2025The Higgs court further explained that "[t]he evidentiary role of the collateral source doctrine acts as a 8 SC-2023-0401 and SC-2023-0424 prophylactic, shielding the jury from evidence that is likely to encourage it to violate the substantive role of the rule." Id. at 1314 . 1 Alabama historically applied the common-law collateral-source rule. | 2 | 2025–2025 |
McCormick v. Bunting
green
1 sentence2016She also relies on Crocker v. Grammer, 87 So.3d 1190 (Ala. Civ.App.2011), and McCormick v. Bunting, 99 So.3d 1248 (Ala.Civ.App.2012), in which this court held that, in enacting § 12-21-45, Aa.Code 1975, 2 the legislature modified the common-law collateral-source rule in order to allow Alabama juries to determine whether an award of damages should be reduced as the result of payments of medical and hospital expenses made by third parties on behalf of a plaintiff. | 1 | 2016–2016 |
Marsh v. Green
green
1 sentence2011Based on that substantive rule of law, see American Legion Post No. 57 v. Leakey, 681 So.2d 1337, 1343 (Ala.1996), overruled on other grounds by Marsh v. Green, 782 So.2d 223 (Ala.2000) (holding that the collateral-source rule “as a whole is a rule of substantive law,” but one that contains a procedural component (emphasis omitted)), evidence of third-party payments of medical and hospital expenses was not admissible in personal-injury actions because such evidence was irrelevant to the issue of the appropriate measure of damages and unduly prejudicial to the plaintiff if used for other purpos | 1 | 2011–2011 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
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.