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Coyne v. Campbell

Citation. 183 N.E. 2d 891 (1962)
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Brief Fact Summary.

A Court of Appeals in New York held that when medical services are provided free of cost any party that is injured by those medical services cannot recover damages in a negligence case. 

Synopsis of Rule of Law.

When a patient receives medical services that are provided free of charge and is injured as a result of these medical services, the injured party cannot recover damages based on a negligence claim. 


Coyne (Plaintiff) suffered an injury after being rear-ended in a car accident. Coyne is a practicing physician and surgeon who has many colleagues in his respective field. After the accident, he received medical treatment from his colleagues at no cost to him. Coyne then proceeded to sue Campbell (Defendant) for monetary damages resulting from the medical expenses. Trial court held he could not recover the medical expenses. 


When a plaintiff receives free medical care can the plaintiff recover what would normally be the cost of those medical expenses? 


No. The court emphasized that a plaintiff can only recover compensatory damages from which he directly paid. 


Believes the defendant should be liable for the cost of the medical expenses despite the fact that the plaintiff never paid any money to receive these medical benefits. 


Expands on the majority’s opinion by stating the injured party would be unjustly enriched if he was allowed to recover damages from which he did not pay. 


The appellate court determined that only money that is paid by the injured party is recoverable despite any moral obligation the plaintiff may now have to the medical provider who rendered free medical services. 

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