Background
Shawn Griffin, Jr. filed suit against United Services Automobile Association and the individual defendants in Louisiana’s 19th Judicial District Court. Thomas Enright, Jr., Erin Bernard Stratton, and Patrick Enright sought supervisory review of an August 17, 2026 judgment granting Griffin’s motion in limine.
The trial court ruled that the jury would not be told that any medical funding company had paid or agreed to pay any of Griffin’s medical bills. The writ application placed that evidentiary ruling before the Louisiana Court of Appeal, First Circuit.
The Court’s Holding
The court granted the writ in part and denied it in part. It recognized that the version of La. R.S. 9:2800.27(F) in effect when the cause of action arose permitted the jury to learn only the amount billed by a medical provider and prohibited disclosure of whether another person, a health insurer, or Medicare had paid or agreed to pay any portion of the claimant’s medical expenses.
The court also relied on La. Code Evid. art. 409, which generally bars evidence of paying or offering to pay injury-related expenses when offered to prove, mitigate, reduce, or avoid liability, but permits such evidence when offered solely for another purpose. It therefore reversed the order only to the extent that it categorically barred evidence relating to Prove Partners, LLC when offered for another purpose. The court denied the writ in all other respects.
Judge Fields dissented and would have denied the writ because, in his view, the criteria for supervisory review under Herlitz Construction Co., Inc. v. Hotel Investors of New Iberia, Inc., 396 So. 2d 878 (La. 1981) (per curiam), were not met.
Key Takeaways
- The jury may not be told that a medical funding company paid or agreed to pay the plaintiff’s medical bills merely to prove or reduce liability.
- Evidence involving Prove Partners, LLC is not categorically excluded if it is offered solely for another permissible purpose under Louisiana Code of Evidence article 409.
- The appellate court otherwise left the trial court’s motion-in-limine ruling intact.
Why It Matters
The ruling distinguishes between disclosing third-party payment of medical expenses for a prohibited liability-related purpose and introducing evidence concerning a medical funding company for some other permissible evidentiary purpose. A motion in limine cannot impose a categorical exclusion broader than the governing evidence rule permits.
The decision is narrow: it does not identify a specific alternative purpose, hold that particular evidence is admissible at trial, or disturb the remainder of the trial court’s ruling.