Court of Appeals Rules UIM Payments Made Before a Verdict Constitute a Collateral Source Subtracted From the Jury Verdict

In the recent case of Russell v. Haji-Ali, the Minnesota Court of Appeals held in a published opinion that receipt of UIM payments prior to verdict against the tortfeasor constitute a collateral source under Minn. Stat. § 548.251 and reduce the plaintiff’s verdict dollar-for-dollar. — N.W.2d –, 2013 WL 141723 (Minn. Ct. App. 2013). However, a pre-verdict UIM settlement with subrogation rights is not a collateral source.  Read the rest of this entry…

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