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California Court of Appeal

Luttrell v. Island Pacific Supermarkets, Inc., A134089

In a personal injury action, the trial court properly applied Howell v. Hamilton Meats, specifically that: 1) Howell governs to reduce the recovery of past medical expenses to the amounts actually paid by Medicare and Medi-cal rather than the amount billed; and 2) the Howell cap should be imposed before any reduction for failure to mitigate damages.

Appellate Information

  • Decided 04/08/2013
  • Published 04/08/2013




  • California Court of Appeal


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