Venditto v. Cadoret
If insurance premiums are greater than the amount paid by insurance combined with insurance adjustments, a defendant may not be entitled to a collateral source reduction. The defendant moved for a collateral source reduction after a jury awarded the plaintiff, Gregory Venditto, $23,028 in economic damages. The court found that insurance paid $7,461. The defendant did not provide the court with evidence that reductions or adjustments were required by insurance contracts or agreements. Premiums of $19,028, which were paid by or on behalf of the plaintiff, were greater than the $7,461 paid by insurance plus adjustments of $8,079. The court denied the defendant's motion for a collateral source reduction and granted judgment to the plaintiff in the amount of $74,438, plus costs of $3,711.