UT: Negotiated Medical Bill Reflects Actual Loss Incurred

Gardner v. Norman, 2025 UT 47, ¶ 41, 582 P.3d 717, 727 (2025) (“Under the collateral source rule, the fact that the negotiated charge was paid by a third party is inadmissible and cannot reduce the plaintiff’s recovery. But the amount of the negotiated charge reflects the actual loss incurred, which is the measure of special damages.”).