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  • Our Team
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    • Insurance Coverage
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    • Laws By State
    • Published Articles
    • MWL Published Books
      • Automobile Insurance Subrogation In All 50 States
      • Fundamentals of Insurance Coverage In All 50 States
      • Workers’ Compensation Subrogation In All 50 States
      • ERISA and Health Insurance Subrogation in All 50 States
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January 28, 2026

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  4. 28

Utah Supreme Court Redefines Recoverable Medical Expenses In Tort Cases

Newsletter, SubrogationBy Payton WhiteJanuary 28, 2026

On October 30, 2025, the Utah Supreme Court finally took a position regarding that state’s Collateral Source Rule and the recovery of medical expenses in tort cases. In Gardner v. Norman, 2025 WL 3030153 (Utah 2025), a unanimous court fundamentally reshaped Utah law governing the recovery of medical expenses and clarified the application of its…

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