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Miller v. State Farm Ins. Co., 993 A.2d 1049 (Del. 2010)

In this case, plaintiff brought a suit against a 3rd party tortfeasor and his own insurance company for UIM benefits, for injuries suffered as a result of a motor vehicle accident. Plaintiff had received worker's compensation benefits for injuries suffered in the subject accident. The 3rd party tortfeasor settled with plaintiff and the worker's compensation carrier accepted a portion of that recovery in reimbursement of its lien. The trial proceeded only as to the UIM carrier. At trial, the Court allowed the evidence of satisfaction of the lien and payments made by plaintiff's worker's compensation carrier into evidence. The Supreme Court reversed and remanded, holding that the collateral source rule prohibited evidence of the fact that plaintiff received worker's compensation benefits. The collateral source rule states "a person deemed legally responsible to another cannot claim the benefit of the ability of the injured party to recover from a third party expenses related to the injury." The Court reasoned that the evidence should be excluded based upon the prejudice to the jury in hearing that evidence and being reluctant to then award a plaintiff a "double recovery."


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