Articles From Hon. James G. Fitzgerald Smith | Illinois State Bar Association

Reasonableness and the admission of an unpaid bill into evidence: Kunz v. Little Company of Mary Hospital and Health Care Centers By Hon. James G. Fitzgerald Smith Civil Practice and Procedure, September 2007 In this medical malpractice case, the First District Appellate Court interpreted Arthur v. Catour, 216 Ill. 2d 72, 833 N.E.2d 847 (2005), an Illinois Supreme Court case that held for the first time that unpaid medical bills may be introduced into evidence under the collateral source rule.

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