Overview of Pebley v. Santa Clara Organics, LLC
This case concerns the admissibility of evidence regarding medical expenses when an insured plaintiff seeks treatment outside of their insurance plan.
In Pebley, the plaintiff (Pebley) opted to receive medical treatment from providers outside of his health insurance plan after he was injured in an accident caused by the defendants. The defendants argued that Pebley should have been limited to recovering the amount his insurance company would have paid had he treated within his insurance plan. The trial court disagreed and allowed evidence of Pebley's full medical bills, including the unpaid bills of providers who treated him on a lien basis.
The California Court of Appeal for the Second District upheld the trial court’s ruling. The court held that an insured plaintiff who receives medical treatment outside of their insurance plan should be treated as uninsured for the purpose of determining economic damages. The court reasoned that because Pebley was personally liable for the cost of his medical care, he was entitled to present evidence of his full medical bills as proof of the amount incurred and the reasonable value of his medical expenses. The court further determined that evidence of Pebley’s insurance was irrelevant and inadmissible because it could confuse or mislead the jury.
The court in Pebley distinguished prior case law, like Howell v. Hamilton Meats & Provisions, Inc., that limited the admissibility of medical bills in cases involving insured plaintiffs. Howell held that an insured plaintiff can only recover the amount paid by their insurer for medical services and not the full amount billed, which is often higher. Pebley distinguished itself from Howell by reasoning that Pebley was personally liable for his medical bills, and his situation was analogous to that of an uninsured plaintiff.
This case is important because it clarifies the rules regarding medical damages for insured plaintiffs who choose to treat outside of their health insurance plans. The court’s holding allows those plaintiffs to introduce evidence of their full medical bills to prove their damages, placing them in the same position as uninsured plaintiffs.

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