Section 1 Introduction

• Library: Damages 2012

Under Missouri law, a claimant may recover for medical and hospital expenses—including expenses for chiropractic treatment—that were directly caused by a tortious act and that have been or are reasonably certain to be incurred to the extent of the reasonable value of the expenses. Wilcox v. Swenson, 324 S.W.2d 664, 672–73 (Mo. 1959). Three fundamental elements are necessary for the recovery of these damages:

1. The claimant must show that the expenses have been incurred or are reasonably certain to be...