Squicquero v. Ross

13 Pa. D. & C.5th 58
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedMarch 24, 2010
Docketno. 10090 of 2005, C.A.
StatusPublished

This text of 13 Pa. D. & C.5th 58 (Squicquero v. Ross) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Squicquero v. Ross, 13 Pa. D. & C.5th 58 (Pa. Super. Ct. 2010).

Opinion

MOTTO, J,

Before the court for disposition is the motion for post-trial relief filed by the [60]*60defendants following a jury trial that resulted in a verdict in favor of plaintiff and against the defendants. This action arose from an incident that occurred on May 11, 2003 when the plaintiff Stephanie Squicquero was a passenger in an automobile stopped for a traffic signal. While stopped, a tree located on the property of the defendants fell onto the Squicquero automobile, causing serious and extensive injury to plaintiff’s left arm. In bringing this action against the defendants, the plaintiff maintained that the defendants knew or should have known that the tree was diseased and rotted; that they knew or should have known that the condition of the tree created a dangerous condition; and that the defendants failed to take action to correct the dangerous condition by removing the tree. The jury found that the defendants were negligent, that the negligence of the defendants was a substantial factor in bringing about the harm to the plaintiff and awarded damages for past medical expenses, future medical expenses, pain and suffering, embarrassment and humiliation, loss of enjoyment of life, and disfigurement. Defendants’ post-trial motion raises the following issues:

(1) Was it error for the court to permit the plaintiff to introduce evidence of plaintiff’s past medical bills paid by the Department of Public Welfare (DPW).

(2) Should the court have excluded the identification testimony of Larry Shaffer.

(3) Did the plaintiff’s evidence fail to establish a basis for a finding of negligence on the part of the defendants.

[61]*61I. EVIDENCE OF PAST MEDICAL BILLS

Defendants argue that plaintiff should have been precluded from recovering the medical expenses that were paid by the Commonwealth of Pennsylvania, Department of Public Welfare based upon the holding in Tristani v. Richmond, 609 F. Supp.2d 423 (W.D. Pa. 2009).

In Tristani, the Pennsylvania Department of Public Welfare placed liens on settlement proceeds obtained from third parties by recipients of Medicaid benefits. The settlement proceeds resulted from personal injury actions instituted by the recipients of the Medicaid benefits. The Tristani court held that, although DPW can require an assignment of the right to receive payments for medical care, and can also demand as a condition of Medicaid eligibility that the recipient assign in advance any payments that may constitute reimbursement for medical costs; nevertheless, DPW cannot force an assignment of, or place a lien on, any portion of the general property of a recipient of benefits including settlement proceeds not specifically allocated to medical payments. Thus, the lien placed by DPW upon the general settlement proceeds was unlawful, as violative of the anti-lien provisions of the Social Security Act, 42 U.S.C. §1396 et seq.

However, in holding that DPW was prohibited from asserting a lien against the general property of the recipient of benefits paid by Medicaid for medical expenses, the Tristani court did not infringe upon the right of those recipients to collect payments for medical expenses in a third-party action. Tristani held that the department has the option of pursuing a direct action against liable third parties or can intervene in an action brought [62]*62by a Medicaid beneficiary against a liable third party. Tristani, 609 F. Supp.2d at 486. However, Tristani does not affect the ability of a Medicaid recipient to pursue claims against a liable third party and collect the full amount of medical expenses incurred as the result of the injury. Tristani made it explicit that the Medicaid recipient retained the right to recover for medical expenses paid for by the Medicaid program, specifically stating the following:

“Pennsylvania law permits a Medicaid recipient to include medical expenses paid for by the Medicaid program within his or her claim against a liable third party. 62 Pa.C.S. §1409(b)(5)(vi)“Although DPW had the option of commencing its own actions against the liable third parties to reimburse itself for the expenditures incurred in providing medical assistance to Tristani and Valenta, these two individuals never lost the option of including those expenditures within their own claims.” Tristani, 609 F. Supp.2d at 472.

Defendants further argue that plaintiff is precluded from recovering the medical expenses paid for by the DPW pursuant to the Pennsylvania Motor Vehicle Financial Responsibility Law, specifically 75 Pa.C.S. §1722. Such section provides as follows:

“In any action for damages against a tort-feasor, or in any uninsured or underinsured motorist proceeding, arising out of the maintenance or use of a motor vehicle, a person who is eligible to receive benefits under the coverages set forth in this subchapter, or workers’ compensation, or any program, group contract or other arrangement for payment of benefits as defined in section 1719 (relating to coordination of benefits) shall be precluded [63]*63from recovering the amount of benefits paid or payable under this subchapter, or workers’ compensation, or any program, group contract or other arrangement for payment of benefits as defined in section 1719.”

75 Pa.C.S. §1719 provides: “As used in this section the term ‘program, group contract or other arrangement’ includes, but is not limited to, benefits payable by a hospital plan corporation or a professional health service corporation subject to 40 Pa.C.S. ch. 61 (relating to hospital plan corporations) or 63 (relating to professional health services plan corporations).”

Benefits paid for medical expenses through the Department of Public Welfare constitute payments made by a governmental agency and is not a program, group contract or other arrangements contemplated by section 1719, and is not a hospital plan or a professional health service corporation. The Medicaid program is authorized pursuant to the Social Security Act. Congress appropriated funds to enable the states to provide medical assistance for those whose income and resources are insufficient to meet the costs of necessary medical services. 42 U.S.C. §1396. The Medicaid program involves cooperation between the states and federal government. Depending upon the particular states’ per capita income, the federal government pays anywhere between 50 percent and 83 percent of the costs that the state incurs for providing medical assistance to those who are eligible to receive it. 42 U.S.C. §1396d(b). Tristani v. Richmond, 609 F. Supp.2d at 440.

In Browne v. Nationwide Mutual Insurance Company, 449 Pa. Super. 661, 674 A.2d 1127 (1996), the Superior Court held that Social Security disability benefits should [64]*64not be deducted from an arbitration award under the terms of section 1722 of the Motor Vehicle Financial Responsibility Law as Social Security disability payments were not encompassed in a language of “any program, group contract or other arrangement.” The Browne

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Bluebook (online)
13 Pa. D. & C.5th 58, Counsel Stack Legal Research, https://law.counselstack.com/opinion/squicquero-v-ross-pactcompllawren-2010.