The Colorado Supreme Court issued its opinion in In re Smith v. Jeppsen on April 30, 2012.
Insurance—Collateral Source—Evidence—Statutory Interpretation.
The Supreme Court held that CRS § 10-1-135(10)(a) codifies the common law pre-verdict component of the collateral source rule prohibiting the admission at trial of evidence of the amount paid by a tort plaintiff’s insurance company pursuant to the plaintiff’s medical expense coverage. The trial court correctly applied CRS § 10-1-135(10)(a) prospectively in this action to exclude from trial evidence of the amount paid by a collateral source. The Court therefore discharged the rule to show cause.
Summary and full case available here.