The following excerpt is from San Joaquin Valley Ins. Auth. v. Gallagher Benefit Servs., Case No. 1:17-cv-00861-EPG (E.D. Cal. 2020):
Under California law, a plaintiff is normally "entitled to no more than a single recovery for each distinct item of compensable damages supported by the evidence," "[r]egardless of the nature and number of legal theories advanced by the plaintiff." Tavaglione v. Billings, 847 P.2d 574, 580 (Cal. 1993) (citation omitted). Thus, "[d]ouble or duplicative recovery for the same items of damage amounts to overcompensation and is therefore prohibited." Id.
The "collateral source rule," is an exception to the prohibition against double recovery, providing that "if an injured party receives some compensation for his injuries from a source wholly independent of the tortfeasor, such payment should not be deducted from the damages which the plaintiff would otherwise collect from the tortfeasor." Helfend v. S. Cal. Rapid Transit
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Dist., 465 P.2d 61, 63 (Cal. 1970).
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