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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


    Background:

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

    Leighton filed suit against his employer, CSX
    Transportation, Inc. ("CSX") under the Federal Employers' Liability Act ("FELA"), 45 U.S.C. 51 et seq. for injuries he
    sustained in the course of his employment. He sought damages for medical
    expenses 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 per
    their 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 to
    Leighton. Leighton wanted the trial court to exclude any evidence that he received
    payments 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 he
    paid out-of-pocket (the remaining $3,000).

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

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

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


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