Corenbaum

This case requires us to consider the impact and implications of the California Supreme Court’s opinion in Howell v. Hamilton Meats & Provisions, Inc. (2011) 52 Cal.4th 541 [ 129 Cal.Rptr.3d 325 , 257 P.3d 1130 ] (Howell). As in Howell, the medical providers who treated plaintiffs in this case accepted, pursuant to prior agreements, less than the full amount of their medical billings as payment in full for their services. We must determine the admissibility in evidence of the full amount of an injured plaintiff’s medical billings not only with respect to damages for past medical expenses, but also with respect to future medical expenses and noneconomic damages.

John Corenbaum and Charles Carter (Carter) suffered injuries when a vehicle driven by Dwight Eric Lampkin collided with a taxicab in which they were passengers. Lampkin was convicted of fleeing the scene of an injury accident (Veh. Code, § 20001, subd. (a)), but was not found guilty on another count for driving under the influence (id., § 23153, subd. (a)). Corenbaum, Carter and Daniella Carter then filed two civil actions against Lampkin, which were later consolidated. After a trial, the jury found that Corenbaum…