In Deck v. Teasley, the Missouri Supreme Court held a plaintiff can recover the "value" of medical expenses, based on the amount billed, even though neither the plaintiff, nor anyone else, paid the full "value" amount or was ever obligated to pay that amount. This is a surprising result for two main reasons: 1) it departs from the Court's own precedent of tort awards being "compensatory only"; and 2) ironically, it relies on a statute from Missouri's 2005 Tort Reform, which was undisputedly intended to limit recoveries and not to expand them.
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