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Ronquillo v. EcoClean Home Services, Inc.

2021 CO 82. No. 21SA55. Collateral Source—Evidence—Medical Finance Liens.

December 20, 2021


The Supreme Court reviewed whether a medical finance company is a collateral source for purposes of the pre-verdict evidentiary component of Colorado’s collateral source rule, CRS § 10-1-135(10)(a). The Court held that the medical finance company in this case is not a collateral source because it did not confer a “benefit,” as defined in CRS § 10-1-135(2)(a), onto the injured party. The Court therefore discharged the rule to show cause and remanded the case for further proceedings.

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