Ronquillo v. EcoClean
Annotate this CaseIn August 2016, Plaintiff Maribel Ronquillo was in an automobile collision. According to her complaint, Ronquillo was rear-ended by defendant Jesse Williams, who was operating a vehicle owned by an EcoClean employee and towing an EcoClean trailer. Ronquillo suffered serious physical injuries and incurred around $250,000 in medical expenses. At the time of the accident, Ronquillo did not have health insurance, so she entered into a medical finance lien agreement with Injury Finance. Under the terms of that agreement, Injury Finance purchased Ronquillo’s accounts receivable from her healthcare providers at a predetermined, discounted contractual rate, which allowed Ronquillo to receive prompt medical care. Ronquillo remained contractually obligated to repay Injury Finance for “all charges billed by the [medical] [p]roviders” regardless of the result of any litigation. Ronquillo and her husband filed suit alleging negligence and loss of consortium against Williams and asserting a respondeat superior claim against EcoClean. As part of discovery, Defendants subpoenaed Injury Finance, seeking information and documents pertaining to Injury Finance’s accounts receivable purchase rates, provider contracts, and business operations and methodologies. When Injury Finance did not respond to the subpoena, Defendants filed a motion to compel production, which the district court granted. Defendants also filed a “motion for determination of a question of law pursuant to C.R.C.P. 56(h) that Injury Finance . . . is not a collateral source[]” subject to the pre-verdict evidentiary component of the collateral source rule. This interlocutory appeal to the Colorado Supreme Court raised the narrow question of whether a medical finance company was a collateral source for purposes of the pre-verdict evidentiary component of Colorado’s collateral source rule. The Supreme Court agreed with the district court that Injury Finance was not a collateral source, "Collateral sources must confer a 'benefit,' as defined in section 10-1-135(2)(a), C.R.S. (2021), onto the injured party. ... Ronquillo has not received a benefit from Injury Finance for purposes of the collateral source rule because her arrangement with Injury Finance does not reduce her financial obligations." The Court expressed no opinion on whether the disputed evidence could be excluded under other evidentiary rules such as CRE 401 and 403.
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