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Coyne v. Campbell

Court of Appeals of New York

183 N.E.2d 891 (1962)

Relevant factsFree

Coyne (plaintiff), a physician, suffered a whiplash injury when Campbell (defendant) rear-ended his vehicle; Coyne's professional colleagues and a nurse provided his medical treatment and care free of charge, and Coyne sought $2,235 in special damages for those services despite never having paid or owed anything for them. The trial court denied recovery for those expenses, and Coyne appealed.

IssueFree

Whether free medical services provided to a plaintiff are recoverable in a negligence action for damages.

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