ML Healthcare Services, LLC v. Publix Super Markets, Inc.

Robin Houston (plaintiff) slipped and fell while grocery shopping at a store owned by Publix Super Markets, Inc. (Publix) (defendant). Houston sought treatment from doctors who had a financial relationship with ML Healthcare Services, LLC (ML Healthcare) (plaintiff). ML Healthcare matched uninsured, injured individuals who had viable tort claims with doctors. The doctors treated the individuals, generating medical bills for the alleged full value of their services, but sold the medical bills to ML Healthcare at a discount. To recoup its expenses, ML Healthcare retained the right to collect the difference between the discounted bill and the amounts claimed by the doctors as the full value of their services from any settlement or judgment collected by the plaintiff. Houston sued Publix, and Publix introduced evidence of the discounted medical bills to prove bias on the part of Houston’s doctors. According to Publix, for ML Healthcare’s business model to succeed, it was necessary for plaintiffs to win their lawsuits, and thus Houston’s doctors were incentivized to overstate the severity of her injuries. The trial court instructed the jury about the collateral-source rule and directed the jury not to reduce any award of damages because of ML Healthcare’s payments. The jury found for Publix, and Houston appealed, arguing that evidence of the discounted bills should have been excluded under the collateral-source rule.