How Does Medical Evidence In Personal Injury Cases Get Presented At Trial?

When you watch courtroom dramas, the focus often revolves around dramatic testimonies, cross-examinations, and surprise witnesses. But have you ever wondered how evidence—such as medical records or bills—gets presented and accepted at trial? In real life, the process of admitting evidence is often far more technical, requiring specific legal tools and strategies to ensure that key documents make it in front of the jury. For plaintiffs in personal injury cases like car accidents, slip and fall claims, nursing home abuse, or product liability, getting certain evidence admitted before trial without unnecessary disputes can make or break the case.

One powerful tool a plaintiff can use to streamline the admission of evidence is Illinois Supreme Court Rule 216: Request to Admit. This rule allows plaintiffs to get facts, documents, and records admitted into evidence without calling unnecessary witnesses. It simplifies the trial process, reduces disputes, and helps plaintiffs keep the focus on the issues that truly matter—like proving liability and damages.

Why Is Medical Evidence So Critical in Personal Injury Trials?

In personal injury trials—whether it’s a car accident, slip and fall or another type of injury claim—medical bills and records are some of the most important evidence presented. These documents not only establish the extent of the plaintiff’s injuries but also prove the financial costs incurred as a result of the accident. Without this evidence, a plaintiff cannot effectively demonstrate the harm they suffered or justify their request for fair compensation.

However, for a jury to consider a damages award, the plaintiff must establish proximate cause—a legal concept that links the injuries to the accident and justifies the damages claimed. This requires proving three key points:

1. The injuries were caused by the accident.
2. The treatment for those injuries was reasonable and necessary.
3. The amount charged for medical care was customary and appropriate for the services provided.

While fault or liability is a critical part of a personal injury case, proving damages—what the injuries have cost the plaintiff physically, emotionally, and financially—is equally important. Without strong medical evidence, the case can fall apart, even if liability is clear. Medical bills and records form the backbone of a damages claim, and presenting them effectively is essential to securing a successful verdict.

This is where Illinois Supreme Court Rule 216 becomes such a valuable tool for plaintiffs. By using a Request to Admit, plaintiffs can establish the authenticity and reasonableness of medical records and bills before trial, ensuring the evidence can be presented efficiently and without unnecessary disputes. This strategic use of Rule 216 helps keep the focus on the most important aspects of the case—proving fault and securing fair compensation—and prevents the trial from getting bogged down in arguments over evidence that should not reasonably be in dispute.

At John J. Malm & Associates, we know that strong medical evidence is critical to achieving a successful outcome for our clients. By strategically leveraging tools like Rule 216, our Illinois accident lawyers make sure that the evidence needed to prove damages is admitted and presented effectively, so our clients have the best possible chance of securing the compensation they deserve.

What Is Rule 216 and How Does It Work?

Rule 216 allows one party—typically the plaintiff—to request that the opposing party admit certain facts or the authenticity of specific documents. The goal of a Rule 216 request is to eliminate unnecessary arguments over facts or documents that should not reasonably be in dispute.

The language of Rule 216(a) is clear:

“A party may serve on any other party a written request for the admission by the latter of the truth of any specified relevant fact set forth in the request or of the genuineness of any relevant documents described in the request.”

For example, in a car accident case, a good Naperville car accident attorney will prepare a carefully worded Rule 216 request asking the defendant to admit the truth of the following:

• That specific medical bills incurred by the injured victim are authentic and were incurred because of the injuries from the accident.
• That the amounts listed on those bills are the customary and usual amountfor the treatment provided.
• That the hospital records are authentic andaccurately reflect the plaintiff’s treatment and resulting condition, which was reasonable and necessary.

Example 1: Medical Bills and Records Requested to be Admitted Before Trial in a Car Accident Case:

1. Admit that the medical records from ABC Hospital accurately reflect treatment provided to the plaintiff on [date] for injuries sustained in the motor vehicle collision on [date of accident].
2. Admit that the treatment provided to the plaintiff, as reflected in the medical records, was reasonable and necessary for the injuries sustained in the collision.
3. Admit that the medical bills from ABC Hospital, totaling $25,000, represent charges that are customary and usual for medical services provided in the relevant geographic area and are fair and reasonable.

Example 2: Medical Bills and Records Requested to be Admitted Before Trial in a Slip-and-Fall Injury Case:

1. Admit that the plaintiff received treatment at XYZ Orthopedic Clinic on [date] because of injuries sustained during the fall on the defendant’s premises on [date of incident].
2. Admit that the treatment described in the medical records from XYZ Orthopedic Clinic was reasonable and necessary to address the injuries caused by the fall.
3. Admit that the charges reflected in the medical bills from XYZ Orthopedic Clinic, totaling $15,000, were customary and usual for the services provided in the relevant geographic area and are fair and reasonable.

If the defendant admits to these requests, the medical bills can be entered into evidence without further proof, saving the plaintiff from having to call medical providers to testify at the trial. This allows the trial to focus on liability and other damages—such as pain and suffering—rather than wasting time arguing over the bills and records themselves.

If the defendant fails to respond to the Rule 216 request within the 28-day deadline, these facts are automatically deemed admitted. This is a significant advantage for plaintiffs because it removes one more obstacle in proving their case.

How Does Rule 216 Overcome “Delay, Deny, Defend” Tactics by the Insurance Company?

Insurance companies often rely on the well-known strategy of delay, deny, defend to avoid paying fair compensation. They delay the claims process, deny responsibility, and aggressively defend against claims in court. Knowledgeable Illinois personal injury attorneys confront these tactics through Requests to Admit. By using Rule 216 strategically, plaintiffs can cut through these tactics:

• Delay: Rule 216 puts a clear deadline on responses, preventing defendants from dragging out the discovery process.
• Deny: If defendants refuse to admit facts or documents without good reason, they risk being exposed in court or sanctioned for their conduct.
• Defend: By securing key admissions early, plaintiffs can streamline their case and focus on presenting evidence that proves liability and damages.

At John J. Malm & Associates, we are a team of award-winning Illinois injury attorneys who know the insurance company playbook inside and out. By leveraging tools like Rule 216, we ensure that the necessary evidence is admitted efficiently, even if the jury never knows the insurance company is behind the defense.

Benefits of Rule 216 for Plaintiffs

For plaintiffs, Rule 216 offers several clear benefits:

1. Simplifies the Trial Process: By eliminating the need to call witnesses to authenticate records, plaintiffs can focus on the most critical aspects of their case.
2. Reduces Costs: Fewer witnesses and streamlined evidence presentation lower the costs of trial preparation.
3. Narrows the Issues: Admitting facts and documents early keeps the trial focused on what really matters—proving liability and damages.
4. Holds Defendants Accountable: Rule 216 forces defendants to respond truthfully and prevents unnecessary disputes over evidence.

“Of all the strategic and procedural tools available to me as a trial lawyer, Illinois Supreme Court Rule 216 is among the most important to me as I prepare my client’s case.  I have successfully used Rule 216 not only to admit medical records and bills into evidence, but also to force the admission of certain issues concerning the defendant’s liability before trial. It can sometimes be difficult for a defense lawyer to sow doubt among the jury after already admitting that the accident injured my client and caused her to suffer damages, like medical bills for the treatment doctors had to perform. Rule 216 allows me to streamline the production of important evidence and focus on the core issues of the case, helping to ensure my clients have the best opportunity to achieve a successful jury verdict at trial.” – Illinois Car Accident Attorney, John J. Malm

Streamlining Evidence with Rule 216

Illinois Supreme Court Rule 216 is a powerful tool that allows plaintiffs to admit key evidence—like medical records and bills—without unnecessary disputes. By securing these admissions, plaintiffs can simplify their case, reduce costs, and focus on proving liability and damages.

At John J. Malm & Associates, we bring over 90 years of collective litigation experience to every case we handle. With millions recovered each year for our clients, our award-winning team of Illinois accident lawyers is dedicated to achieving justice for injury victims. From our offices in Naperville and St. Charles, we provide skilled and strategic representation to help you navigate the complexities of personal injury litigation.

If you’ve been injured and need a team of dedicated Illinois personal injury attorneys that knows how to overcome the obstacles insurance companies put in your way, contact us today for a free consultation. Let us help you build the strongest case possible and secure the compensation you deserve.