Is a dental bill admissible to prove medical expenses incurred as damages?

California, United States of America


The following excerpt is from Jones v. Dumrichob, 63 Cal.App.4th 1258, 74 Cal.Rptr.2d 607 (Cal. App. 1998):

This same exception has been applied to the contested admissibility of a dental bill to prove medical expenses incurred as damages in McAllister v. George (1977) 73 Cal.App.3d 258, 140 Cal.Rptr. 702. In rejecting defendant's objection that the bill was hearsay, the court noted: "In the circumstances of this case this contention lacks merit. Plaintiff testified that the dental services were performed, that he received a bill for them, and that he paid the bill. It has been held that under such circumstances the bill, which ordinarily would constitute inadmissible hearsay, is nevertheless admissible for the limited purpose of corroborating plaintiff's testimony and showing that the charges were reasonable. [Citations.]" (Id. at p. 263, 140 Cal.Rptr. 702.)

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