Trial Court's Exclusion of Evidence Regarding Medical Bills Due to Lack of Expert Proof of Their Being Necessary Upheld on Appeal

The Tennessee Court of Appeals has released its opinion in Holzmer v. Estate of James F. Walsh, Jr., No. M2022-00616-COA-R3-CV (Tenn. Ct. App. July 28, 2023). The syllabus reads:

This is an appeal from a jury verdict awarding damages to a plaintiff injured in a car accident. The plaintiff asserts that the trial court erred in excluding evidence of her medical bills. Because the plaintiff failed to present expert proof that her medical expenses were necessary, we find that the trial court did not abuse its discretion in excluding the bills. The jury verdict is affirmed.

Here is a link to the opinion: 

Majority Opinion M2022-00616-COA-R3-CV.pdf (tncourts.gov)

NOTE: Look for this one to be appealed to the Tennessee Supreme Court. Time will tell.