The collateral source rule and, more generally, pre and post
verdict setoffs of economic damages, have become extremely
complicated under Florida law. For instance, Florida law treats
past medical expenses differently depending on whether they were
paid by Medicare or Medicaid or by private health insurance. In the
case of Medicare or Medicaid, the courts have held that a jury may
hear only the net medical bills after insurance adjustments. In the
case of private health insurance, the courts have held that the
jury may hear the total amount of the bills, although the defense
is likely entitled to a post verdict reduction or setoff. To
further complicate things, other types of insurance, such as
personal injury protection coverage (PIP), are treated differently
than either of the aforementioned types of insurance. In recent
determinations, the Florida Supreme Court has provided additional
guidance in this general area of law. Unfortunately, the
Court's rulings are not
