# Can a claim include medical costs?

Canonical: https://californiapersonalinjurylaws.com/guides/medical-costs/

Reviewed by Andrew (Andy) R. Gillin; publisher reported approval on 2026-11-04. Original review date was not supplied.

## Short answer

A claim may cover care needed because of the injury. The care must be reasonable and needed. The amount you can claim may differ from the price on the bill.

## Hypothetical example

A person keeps bills for a hospital visit and care after a crash.

## How the rule works

Keep the bill, the record of care, and the payment record together. They show different facts. The claim must address both the need for the care and the amount that can be recovered.

## What can change the answer

The amount paid or still owed can matter. So can the link between the care and the crash. Not all care is part of the claim.

## A useful next step

Save each bill and the records of what was paid. Keep records of the care too.

## Court decisions behind this answer

### Howell v. Hamilton Meats & Provisions, Inc. (2011)

52 Cal.4th 541, slip op., pp. 1–2. For the insured care at issue, a bill’s unpaid negotiated writeoff was not a loss the patient could recover.

Limit: This does not decide every bill or lien. Future care and other kinds of loss need separate proof.

Source: https://law.justia.com/cases/california/supreme-court/2011/s179115/

## Sources

- [Civil Code § 3333 — Compensation for harm](https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=CIV&sectionNum=3333.)
- [CACI No. 3903A — Medical expenses (2026 edition)](https://courts.ca.gov/system/files/file/judicial_council_of_california_civil_jury_instructions_2026.pdf)
- [Howell v. Hamilton Meats & Provisions, Inc. (2011) 52 Cal.4th 541](https://law.justia.com/cases/california/supreme-court/2011/s179115/)

General information, not legal advice.