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  • Hoffman v. 21st Century North American Insur…Hoffman v. 21st Century North American Insurance Co.
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Hoffman v. 21st Century North American Insurance Co.

Supreme Court of Louisiana
2015 WL 5776131 (2015)


Eddie Hoffman (plaintiff) and Carolyn Elzy got into a car accident. Hoffman brought suit against Elzy’s insurance company, 21st Century North American Insurance Company (defendant). The trial court ruled in favor of Hoffman as to liability. On the issue of damages, Hoffman introduced medical bills amounting to $4,528. However, 21st Century introduced more detailed medical bills showing that the medical provider had agreed to write-off $2,050 of the charges. Hoffman’s attorney had an arrangement with the medical provider and had negotiated the write-off. The trial court awarded Hoffman $4,500 in general damages and $2,478 in medical-expense damages. The trial court thus did not award Hoffman the $2,050 in medical expenses that had been written off. Hoffman appealed on the issue of damages. The court of appeal affirmed. The Supreme Court of Louisiana granted certiorari.

Rule of Law


Holding and Reasoning (Guidry, J.)

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