Section 4 Voluntary Payments by Third Parties

• Library: Damages 2012

It appears that, if medical and hospital bills for services provided to a claimant are voluntarily paid by a third party who does not expect repayment, those bills are not a proper element of the claimant’s damages. The underlying reasoning is that, under these circumstances, any expenses so discharged have not been incurred by the claimant. But Gentili v. Dimaria, 89 S.W.2d 93, 97 (Mo. App. E.D. 1936), held otherwise when there was no evidence to indicate that the third party who had made a voluntary...