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Jeff Leighton v. CSX Transportation, Inc.

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  • Jeff Leighton v. CSX Transportation, Inc.

    Date Decided: Mar 11th, 2011
    Decided By: Kentucky Court of Appeals (State)
    Court: Court of Appeals of Kentucky
    Citation: 338 S.W.3d 818

    Jeff Leighton ("Leighton") appeals a lower court's denial ofhis motion for a new trial.

    Leighton filed suit against his employer, CSXTransportation, Inc. ("CSX") under the Federal Employers' Liability Act ("FELA"), 45 U.S.C. 51 et seq. for injuries hesustained in the course of his employment. He sought damages for medicalexpenses and lost employment benefits.

    As a result of his injuries, Leighton incurred approximately$11,000 in medical bills. CSX paid all but $3,000 Leighton's medical bills pertheir obligation under The Railroad Employees National Health and Welfare Plan("the Plan").

    At trial, both parties filed motions in limine seeking to exclude evidence of medical expenses paid toLeighton. Leighton wanted the trial court to exclude any evidence that he receivedpayments from insurers or other collateral sources (the $8,000 paid by CSX),and CSX wanted to limit evidence of Leighton's medical expenses to those hepaid out-of-pocket (the remaining $3,000).

    The trial court "struck a balance," ruling Leighton would beable to offer his total medical expenses into evidence ($11,000), but that thecourt would instruct the jury that Leighton could only be awarded $3,000 in medicalexpenses (his out-of-pocket expenses).

    The jury returned a verdict for Leighton, awarding $3,000 inmedical expenses and $5,200 in lost employment benefits. However, the Courtfound Leighton partially at fault for his injuries and reduced the award to$4,300.

    Leighton filed a motion for a new trial arguing the juryinstruction limiting his award of medical expenses was in violation of thecollateral source rule under FELA. The trial court denied his motion andLeighton appealed to the Court of Appeals of Kentucky.