SAN FRANCISCO — When the California Supreme Court two years ago limited medical damages to the amounts insurers actually pay providers — and not the higher rates the provider purports to bill — plaintiffs attorneys weren’t amused. Now they’re going to be angrier still, as the Second District Court of Appeal has applied the same logic to future medical costs and even non-economic damages.

"Howell [v. Hamilton Meats] stated that the full amount billed is not an accurate measure of the value of medical services," Justice H. Walter Croskey wrote Tuesday in Corenbaum v. Lampkin. "For the same reason, the full amount billed for past medical services is not relevant to a determination of the reasonable value of future medical service."

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